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5.2. SR 05-16-1994 r I -'\) ( II fl~ AGENDA ITEM 5.2. MEMORANDUM TO: MAYOR & CITY COUNCIL FROM: STEVE ROHL~MINISTRATOR DATE: MAY 10, 1994 r"'f SUBJECT: FINAL ENVIRONMENTAL IMPACT STATEMENT ON MINERAL EXCAVATION ATTACHMENTS Staffs proposed final Environmental Impact Statement Letter from the Minnesota Department of Natural Resources (DNR) dated 4/4/94 Letter from Minnesota Pollution Control Agency dated 4/6/94 Written correspondence from Bruce Pearson (resident from Ridgewood) Letter from United Power Association dated 3/31/94 e INTRODUCTION Staffs proposed Final Environmental Impact Statement (EIS) on mineral excavation is basically responses to the comments received on the Draft Environmental Impact Statement (DEIS). A summary of each of the comments from the various parties and agencies is found in the final EIS in bold type and the City's response follows. Besides the written comments that are included with this memo, the final EIS responds to the citizens comments from the March 21, 1994, public hearing held by the City Council, comments from the Elk River Planning Commission, and a verbal comment from County Environmental Officer Dave Lucas. The responses to the comments received in the DEIS are actually the middle section of the final EIS. Preceding those responses are a group of summaries; one for each section of the DEIS. Adding these summaries is in response to the DNR's first comment. The back section of the final EIS is information regarding a pumping test that was conducted at the end of March, 1994. This pumping test was conducted to verify assumptions made in the DEIS regarding the aquifer in the study area and what impacts gravel washing operations may have on it. e P.O. Box 490 · 13065 Orono Parkway · Elk River, MN 55330 · (612) 441-7420 · Fax: (612) 441-7425 e PROCESS 1. May 16 - City Council meeting. At this meeting, staff is recommending the City Council find the proposed final EIS acceptable. 2. May 25 - If the Council finds the proposed final EIS acceptable, a press release will be given to the Elk River Star News and the final EIS will be distributed to the appropriate agencies. 3. June 6 - Notice of a ten working day comment period on the final EIS will be published in the Environmental Quality Board Monitor. 4. June 20 - This is the date the comment period on the final EIS ends and the City Council may declare the final EIS adequate or have it revised. 5. June 27 - On or before this date, a Declaration of Adequacy must be sent to the Environmental Quality Board Monitor to be published and the EIS process is completed. SUMMARY e Staff recommends the City Council approve the final EIS for distribution. Staff does not anticipate any public comments at Monday night's meeting because the final EIS is not distributed until the Council okays it. Public comments on the final EIS will be received during the 10 day comment period. The final EIS can be added to the three ring binder that contains the draft EIS. The new EIS cardboard insert can replace the DEIS insert on the outside cover. If you have any questions feel free to contact me prior to the meeting. e e ~ STATE OF [N][N]~~@iJ~ DEPARTMENT OF NATURAL RESOURCES APR 7 199' 500 LAFAYETIE ROAD · ST. PAUl, MINNESOTA · 55155-40 10 DNR INFORMATION (612) 296-6157 April 4, 1994 Stephen Rohlf, Building and Zoning Administrator City of Elk River Elk River City Hall 13065 Orono Parkway Elk River, MN 55330 RE: Elk River Gravel Mining District Draft Environmental Impact Statement (DEIS) Dear Mr. Rohlf: e The Department of Natural Resources (DNR) has reviewed the Draft EIS for the Elk River Gravel Mining District. We commend the City and project proposers for voluntarily undertaking this joint EIS to examine the cumulative environmental effects expected to occur within the proposed gravel mining district. We reco~ze the value of this decision and believe the final product will serve the interests of all mvolved parties. This process, by recognizin~ up front the various natural and social resource values currently produced at this site, wIll provide a planning framework which can most effectively avoid and minimize potential impacts to these same resources. In this regard, the DNR strongly supports your proactive stance and offers the following discussion to highlight issues of particular concern or areas that we believe require further elaboration or clarification. We first offer some general comments which are followed by comments relating to specific document references. Conclusions There is a general lack of analysis for each of the major technical sections (land use, surface water, etc.) with the exception of Air Emissions. The document describes Alternatives A, B, and C in great detail in terms of data, however there are no overall conclusions drawn. The EIS should clearly detail the significant environmental effects expected to result from project implementation. A brief summary should be provided at the end of each section that presents key findings and conclusions with respect to Alternatives A, B, and C. This is an essential component of the environmental review and future planning process. e Vegetation Impacts The EIS should clearly spell out the specific project-related effects on vegetation, particularly regarding the Dry Oak Forest communities found on or near the district, for each of the proposed alternatives. Furthermore, the document should clearly recognize that the natIve woodland communities found in Sherburne County are being rapidly converted to other land uses. This conversion results in the degradation or loss of these communities. Impacts to the Dry Oak Forest woodlands in the project area should ideally be considered in the larger context of planning at the city, township, and county level to provide for the protection of significant natural areas. We have provided a map detailing the remaining natural areas in Sherburne County to assist necessary efforts in this regard. \. AN EQUAL OPPORTUNITY EMPLOYER e e e Stephen Rohlf April 4, 1994 Page 2 Reclamation The document generally construes reclamation to mean the stabilizing of slopes and the re- establishment of vegetation. As indicated in several places, various permits will require the mining companies to take these actions to prevent erosion. Reclamation, however, is a much broader concept than the re-establishment of vegetation. Reclamation in this sense, especially in the case of a gravel mining district covering such an extensive acreage, should be a planning exercise that is aimed at directing mining activities toward a well detailed and coordinated end use. The DEIS indicates that substantial acreage has already been reclaimed by a number of companies. The current reclamation status of these areas should be fully detailed. This analysis should be coupled with an assessment of how the existing reclamation conditions fit with an overall reclamation plan. The DEIS provides a projected schedule for progressive reclamation throughout the life of the mining activity, with some reclamation expected to occur as early as 1994 or 1995. A generalized reclamation plan should be in place to guide all progressive reclamation efforts. We recognize that it is not possible to predict the future in great detail, thus annual planning for reclamation as minin~ advances by means of a city permit is a practical way to deal with it. However, the diSCUSSIon throughout the DEIS suggests alack of a ''big picture" view of final reclamation and end use, and the document could be viewed to present an impression that reclamation will be handled piecemeal on an annual basis.with each individual company. We strongly recommend that long-term planning should.begin now so . that reclamation is a coordinated process among all the mining companies throughout the life of the mining district. A timetable for reclamation planning should parallel the time frame presented for the transportation plan. Tables 2.1-1,2.2-1,2.3-1 and 3.1-2, 3.1-3, 3.1-4 The tables depicting the changes in land use under each alternative are confusing as presented. Do the numbers in the "Trees Within CBS Site" column refer to County Biological Survey site-acres expected to be impacted by mining activities? It is also unclear whether or not the numbers in the tables are cumulative. For example, will 60 total units (acres?) in a CBS site be impacted under Alternative B or will 90 units be impacted, (which is the number reached by adding the Stage 0, Stage 1, and Stage 4 values provided?) Section 3.1 Land Use ,. The document indicates that there are 20 residences, 12 of which are occupied, located within the proposed gravel mining district. Those 12 residences may be the ones most affected by the mining operations. It is appropriate to address in limited fashion the special concerns these people may have and what the final disJ?osition of these properties will be (Le., is there interest on the part of the mining compames to purchase?). There is essentially no discussion in the document regarding mine waste. Is mine waste going to be produced, most likely in the form of overburden, undersize and oversize materials? If so, the EIS should indicate what volumes will be produced and how it will be used or disposed. For example, will mine waste be used in the creation of final landforms e e e Stephen Rohlf April 4, 1994 Page 3 or to backfill pits? Dredged material from settling basins may be considered mine waste and could potentially have some application in reclamation as top dressing. Page 3-1, paragraph 6 This section should clarify the legal and endangerment status of elements identified through the County Biological Survey (CBS). Although natural communities other than Calcareous fens are not currently protected by law in Minnesota, the Natural Heritage Program has classified natural plant commumties and ranked them based upon their relative endangerment in the state. The special concern status of the Mixed Oak Woodland community refers to the status of this natural community type in the entire state, and as such, it is not a site specific status. CBS sites #227 and #239 consist of Dry Oak Forest communities. Section 3.1 and Figure 3.1-1 incorrectly state that these sites have no DNR status. The Dry Oak Forest community type found in CBS sites #227 and #239 has been designated as threatened in the state by the Natural Heritage Program. Both CBS sites #239 and #227 are found within the gravel mining district, and both should be mentioned in this section. Section 3.1.d (Mitigation), pages 3-6 and 3-7 Alternative B is presented as the most likely scenario to occur. There should be more discussion on ways to mitigate the concerns associated with Alternative B. For examtlle, although the natural heritage sites are mentioned in several locations with no diSCUSSIon on possible mitigation or alternatives to mining. The Natural Heritage Pro~amspecifically recommends avoidance of impacts if possible because it would be very difficult to effectively mitigate the impacts of a gravel operation to the natural communities rresent in the district. Of the two sites initially identified as being of concern by the Natura Heritage Program, (#194 and #240), it appears that CBS site #194 will be impacted by the proposed gravel operations. Impacts to this site should be considered in the larger planning context noted above. True protection of these resources requires that they be considered at the city, township, and county level simultaneously; we believe that the current situation provides an opportunity for local planning efforts to include the protection of CBS site #194 as parkland or open space. Similarly, the loss of 40 acres of agricultural land of "statewide SIgnificance" is mentioned as an outcome but there is no discussion on how that loss might be compensated. We recognize that perhaps there are not reasonable ways to mitigate or avoid these losses. Final reclamation to restore elements that were initially on the site may be the only way available to mitigate their loss. If that is the intention, the EIS should explicitly make this statement. In recognizing Elk River's growth potential'; the size of the mining district, the proposer's willingness, and the progressive attitude of the city, there is an unparalleled opportunity to create an exceptional final land use plan for the gravel minin~ district. Final end use, thou~, is not addressed in the DEIS other than to state that It will be compatible with existing city zoning ordinances, mainly residential. Creation of final landforms such as wetlands, open bodies of water, and upland contours are more cost-effective during active mining. WIth forethought, these final landforms can be more interesting than simply 4:1 slopes and square holes. The reclamation plan, for example, should examine the feasibility of establishing such amenities as public parks or green spaces, a golf course, a trail network, or playgrounds. These kinds of features are not only compatible with the proposed residential housing but would enhance the overall community value of the final development. Some type of public space within the 2,700-acre mining district would seem e e e Stephen Rohlf April 4, 1994 Page 4 appropriate, especially considering the projected growth of the Elk River area over the next 75 years. Section 3.2 Surface Water Page 3-9 states that no DNR protected waters are located within the mining district boundaries. However, Wetland 71-0004W is very close, if not located within the boundaries. Other close wetlands or waters which are close include 71-0015P, 170W, 171W, 265W, and 9W. We strongly recommend the consideration of setback establishment for these basins. Furthermore, runoff water from the mining operations must be treated prior to entering the lake. Treatment should include settling basins, or other methods which limit erosion, sedimentation, or discoloration of the waterbodies. It may be feasible to establish permanent settling basins for protected basins, with multiple mining operations contributing runoff to the settling basin. Settling basins should be designed to hold at least a 50-year flood event, with overflow to the wetlands. Ditches, streams, and other waterways should have similar established setbacks, and protection from erosion/sedimentation since they empty into wetland basins and/or rivers and streams. As wetlands are restored, wetland areas should be established. The current landscape likely provides substantial aquifer recharge. Long term, major changes from mining, as well as other subsequent changes in land use, could affect aquifer recharge. Other concerns relating to de-watering may be expressed through DNR water appropriation permits. Since the mining district is divided by a watershed boundary, and minin~ is expected to reach a depth of approximately 100 feet, local water table flow directIOns could be impacted or changed. Such issues will be handled on a case by case manner. Appropriation permits are required for appropriation of water in excess of 10,000 gallons per day, or 1,000,000 gallons per year. Visual inspection of the area by Section of Fisheries personnel leads to concerns about what effect this project will have on the various fisheries related interests in the area. Wetland impacts, both direct and indirect, along with changes in land use, can lead to fishery impacts. We are concerned that the increase in mining activity will alter future land use patterns in way which may ultimately increase erosion and decrease water quality leaVing the project site. Our specific concerns include: 1. Reduced water quality from this I;>roject expansion can negatively impact two river systems because the project site SItS at the boundary of the Rum and Mississippi River watersheds. The onsite treatment of storm- and waste- waters will significantly reduce concerns in this regard. 2. Wetlands found both within and outside the mining district require protective measures designed to control erosional impacts. 3. Northern pike from the Elk River and Orono Lake run up a small stream to a series of small wetlands that are adjacent to the project site. Additionally, Northern pike run from Fremont Lake (71-16) to the marshy area in and around Rice Lake (71- 78). Efforts should be taken to avoid impacts to these locally important fishery resources. We have provided a map that generically details the areas in questIOn. e e e Stephen Rohlf April 4, 1994 Page 5 The EIS should recognize that the project has potential fishery impacts. Please contact John Hiebert, Natural Resource Specialist, Montrose, at (612) 675-3301, for further information regarding how the project can be designed to avoid these impacts. Section 3.4 Noise Backup beepers on heavy equipment are often cited by the public as one of the most offensIve sources of noise that originate from mining operations. Were backup bee)?ers a consideration in the noise pollution study and have they been an issue with the public? Section 3.6 Sociologic and Economic The Sociological section indicates that Elk River has grown by 64% in the 1980s. The document would be stronger if it included a discussion on: 1) the future demand for aggregate inthe Elk River area (as implied by the growth rate in the 1980s), 2) the current rate of aggregate consumption and the projected rate, 3) the cost of obtaining aggregate from other sources rather than from the mIning district, and 4) a brief discussion on the costs of longer haul distances. Overall, the advantages to the p'ublic and the city of continuing a gravel mining district to provide a local and readily available source of aggregate are not succinctly stated; we believe this to be an extremely important aspect of the EIS. Sherburne County collects the Aggre~ate Material Tax money, 10% of which is dedicated to a special reserve fund for reclamatIOn. The current language of the statute restricts use of these monies for projects on public lands. Has the County considered what it will do with the substantial reclamation reserve monies that will be generated from this tax? Are avenues available through which this money could be used to enhance progressive reclamation by the mining companies within the gravel district? If it is possible that the Elk River Landfill will expand substantially in the future into the proposed mining area, then future plans for the expansion and closure of the landfill over the next 75 years should be briefly highlighted in the EIS. Section 4.1, III. C. Traffic The DEIS does not discuss haul routes outside the mining district, as well as omitting discussion of average daily traffic (ADT) statistics along those routes attributable to mining. Has truck traffic been an issue with the public and will it substantially increase with an expansion in mining? Concluding Remarks As previously stated, the DNR stron~ly supports this joint environmental review and planning effort. The document reqUIres continued refinement, particularly in terms of Impact assessment. However, we are impressed by the progress made to this point. Issues regarding the sensitive forest elements, the overall reclamation scheme, and water quality protection dominate our view of the proposal from a natural resources perspective. We are willing to provide advice or assistance where appropriate in addressing these concerns. '\. Thank you for the opportunity to review this document. Please contact me at (612) 296- 4796 if you have interest regarding our offer of limited assistance or questions regarding e e e Stephen Rohlf April 4, 1994 Page 6 other aspects our comments provided in this letter. We look forward to receiving the final EIS. Sincerely, ~~/0'~ Thomas W. Balcom, Supervisor Natural Resources EnVIronmental Review Section Office of Planning : enclosure c: Bob Hance Steve Colvin Pete Otterson Maryanna Harstad John Hiebert, Natural Resource Specialist, Montrose Jan Shaw Wolff Lynn M. Lewis, USFWS Gregg Downing, EQB #930144-02/ER12.ELKGRA VL.DOC \. e APH 7 195'4 Minnesota Pollution Control Agency April 6, 1994 Mr. Steven Rohlf Ci ty Hall 13065 Orono Parkway Elk River, Minnesota 55330 RE: Elk River Gravel Mining nj~trict, En"iron~ental Impact St~t~mcnt Dear Mr. Rohlf: The above document has been reviewed by the Minnesota Pollution Control Agency (MPCA) staff. We offer the following comments for your consideration. e The MPCA staff commends the city and the various mining companies involved for their cooperative effort in developing the Environmental Impact Statement (EIS). Environmental review benefits from a broad scope approach such as you have taken, rather than dealing with individual and neighboring mines on a piecemeal basis. In many ways your work can serve as a model for other local governments conducting environmental review of mining areas. We also appreciate the time taken by city staff to meet with the MPCA staff on March 18, 1994, and discuss issues in connection with this EIS. Our staff's discussion with the city suggests that the city shares our view that surface water ponds and lakes left in the mine pits will serve as valuable recreation, fisheries, and wildlife resources. We are pleased to learn that in the post-mining development of the district, when land uses convert to residential, commercial, and industrial purposes, the city will require that best management practices (BMPs) are implemented to protect these abandoned pit waters. In particular, the city has told ollr staff that BMPs such as sedimentation basins and skimmers would be used to treat storm water before it enters the pit waters. We would like to stress that such pits should not be utilized for treatment of storm water, in part because of concerns that the pits can provide an easy pathway for contaminants to reach ground water. We suggest that the city consider the feasibility of routing post-mining storm water (particularly that generated in the vicinity of the landfill) away from the ponds left in the pits, so as to maintain the long-term quality of these ponds. We strongly recommend that, in the final EIS, the city stress this approach to post-mining storm water management in the mining district, since we believe it is important to document for future water quality planning efforts. e The EIS should note concerns over how mining in the north part of the district might potentially affect leachate contaminant movement from the landfill. 520 Lafayette Rd. N.; St. Paul, MN 55155-4194; (612) 296-6300 (voice); (612) 282-5332 (TTY) Regional Offices: Duluth. Brainerd. Detroit Lakes. Marshall. Rochester Equal Opportunity Employer. Printed on recycled paper containing at least 10% fibers from paper recycled by consumers. e e e Mr. Steven Rohlf Page 2 Ve would like to note that Elk River is within a region of the state, north of the Twin Cities along the Mississippi River Valley, in which the MPCA hopes to improve ambient ground water quality monitoring. In particular, well igwb0010, at 19861 Gary Street in Elk River, may be included in this network; this well seems to be down gradient of the mining district and may be a useful reference point in the future to track potential impacts of development, mining and non-mining, on the local ground water. Ve are pleased to see that the EIS addresses in detail the Pollution Prevention Plans required by the National Pollutant Discharge Elimination System (NPDES) storm water permit program. It is not clear from MPCA records, however, whether each of the active mining and aggregate production operations in the Elk River mining district indeed has prepared and begun to implement their respective plans. In particular, we question the status of these plans for Barton, Bauerly Brothers, Elk River Bituminous, Midwest Asphalt, and Plaisted at their respective Elk River facilities. Ve recommend that you contact each firm and request to review each of their plans, and then indicate in the final EIS where the city believes each firm is with respect to storm water compliance. This would be helpful in better meshing the city's water quality management efforts, which appear to be well planned, with state and federal storm water permitting requirements. The MPCA staff expects each of the mining companies, as well as other industrial facilities like AME Ready Mix and Shiely Masonry, to fully comply with the requirements of the NPDES storm water program so as to protect local waters from runoff impacts. Page 3-53 of the EIS discusses chemical treatment as a means of dust suppression. Vhile this is a generally accepted method to control fugitive dust, we recommend that chemical application be discouraged whenever there are feasible alternatives, so as to minimize surface and ground water contamination by the chemicals. Regarding air quality matters, we note that the air quality section of the EIS, specifically pages 3-44 to 3-47 and table 3.5-2, gives emission factors for the various operations and total expected emissions from the facilities, but does not give the facility basis for each site. MPCA thus has no way of verifying that the totals given are correct. It also appears that some of the emission factors used may have been extracted from the wrong reference. John V. Ferman of the MPCA Air Quality Division (296-7600) should be contacted to discuss this matter. e e e Mr. Steven Rohlf Page 3 Ve appreciate the opportunity to review this document, and look forward to receIvIng your responses to our comments and the final EIS. Please contact Villiam J. Lynott, of my staff at 296-7794, if further discussion is desired. Si.ncerely, ~~ Paul Hoff, Director Environmental Analysis Office Administrative Services Division PH : j r cc: Dick Peterson, Barton Sand and Gravel, Maple Grove Laurie Seifert~Kissner, Bauerly Brothers, Inc., Sauk Rapids Jerry Hicks, Elk River Bituminous, Elk River Dave Blanski, Midwest Asphalt, Hopkins Ed Egan, Plaisted Company, Elk River AME Ready Mix, Elk River Bob Bieraugel, Shiely Company, Egan Bruce S. Olson, Minnesota Department of Health Paul Diedrich, Minnesota Department of Natural Resources, Fisheries David Pauly, Minnesota Department of Natural Resources, Vildlife Dale Homuth, Minnesota Department of Natural Resources, Vaters Gary Elftmann, CORPS of Engineers, St. Paul Sherburne Soil and Vater Conservation District Sherburne County Planning and Zoning John Lichter, B.A. Liesch Associates, Inc. John V. Ferman, MPCA Air Quality Division '[\. , APR - 1 199 e BASED ON SPEECH GIVEN AT THE MARCH 21 ST CITY COUNCIL MEETING IN REGARD TO GRAVEL MINING IN THE CITY OF ELK RIVER As a long time resident of Elk River, I am becoming increasingly concerned about what is happening to our city. When I moved here in 1966, people spoke of what a lovely charming town Elk River was. They spoke of the rivers that wind through our city, of Lake Orono, and the beautiful woods that framed our city. Real estate agents often referred to Elk River as being the ideal location - only a short drive to downtown Minneapolis and still maintaining the charm and beauty of a small town. e Well, a lot has happened since 1966. The river still winds through the city, but we have done nothing to make that a focal point or drawing card for our town. Our back is still to it. Lake Orono is still there for now; how long will it be before it is only a silt-filled marsh? And the woods; what are we doing to preserve what we have? We're here tonight to hear about expanding gravel mining in the city of Elk River. How many of you want our city to look like the eye sore that exists at County Road 33 and Highway 169? I get the impression that gravel mining expansion in our city is a foregone conclusion and only the amount of buffer is being considered. We don't want any more eyesores. Our city is on the road to being aesthetically bankrupt. e After speaking to Mr. Rohlf, I was tbld about the gravel mining company's plan to reforest their abandoned pits. It took over 50 years to grow the trees in the area north of Ridgewood. Do you want to look at the remains of an abandoned pit for 50 years in hopes that we will get back what we already have? Many of us is this room have added a little weight. How did it get there? One mouthful at a time. When we look at our city a few years from now, are we going to ask how it lost its charm? Is the answer going to be one acre of gravel at a time? e The only possible reason you are even considering a variance is to pad the city coffers. Let's be more forward looking. The decision you make concerning the gravel mining expansion will, no doubt, affect what Elk River is to become. Much of the land in question is designated for single family dwellings. Don't you think that forested lots will draw nicer homes and therefore more taxes? Just compare the taxes of the Ridgewood and Brentwood residents with the residents who live on reclaimed - reforested fields. You have a difficult decision to make. I hope you will make the decision to preserve what charm is left of Elk River and to vote to ban gravel mining expansion in our city. Let's not have Elk River's new nickname be the Gravel Pit of Minnesota. Thank you, · ~ IL.J Bruce Pearson 19874 Watson Street Elk River, MN 55330 e e ~~ United Power Association P.o. Box 800 . Elk River, MN 55330-0800 . (612) 441-3121 APIi -, ;99, March 31, 1994 Mr. Stephen Rohlf Building and Zoning Administration City of Elk River 13065 Orono Road Elk River, MN 55330 Dear Mr. Rohlf: e This letter is to notify the City of Elk River, that United Power Association (UP A) is very concerned about several issues as a result of the proposed Gravel Mining District. I have reviewed the Draft Environmental Impact Statement (DEIS) prepared by the City. There are several issues which UP A believes have not been adequately addressed. These issues are stated below: . Adequacy of 4:1 slope in vicinity of UP A's radio tower to withstand erosion. . Impact on "utilities" as defined in Alternative B & C does not adequately address the impact, or mitigation methods. . Paragraph 1, page 3.7 implies that UPA will bear the cost of relocation expenses. . No member of the UPA management or statTwas ever contacted during the writing of the DEIS for input. . Proposed final contour of 1050 AMSL is 30 feet below surveyed elevation of tower which is 1080 AMSL. e The radio tower in the proposed mining area is a hub facility in a very extensive microwave radio system that UP A utilizes to control electric generation and transmission facilities in the states of Minnesota, North Dakota and Wisconsin. Relocation of this facility is very costly, and potentially not feasible; there are numerous technical issues that must be investigated. Mr. Stephen Rohlf March 31, 1994 Page 2 e UP A is opposed to any relocation of this tower based on the limited study given to the issues in the DEIS. I look forward to receiving notices offuture meetings regarding this Issue. Sincerely, UNITED POWER ~SOC}ATION ~;;(.~~ James L. Goodin, Manager Telecommunications Engineering JLG/kg c: Tom Larson Jim Eggen e \~. :~.- -., ... .~ .. ',) e ::.';;:' -:~~-:;~ r..