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3.1. & 3.2. PCSR 06-23-2009REQUEST FOR ACTION To Item Number Plannin Commission 3.1. & 3.2. Agenda Section Meeting Date Prepared by Plannin une 23, 2009 Rebecca Hau ,Environmental Admin Item Description Reviewed by 3.1. Request by Elk River Landfill, Inc. for Land Use Lori ohnson, Ci Administrator Amendment to change the Land Use of Certain Reviewed by Property from Mining to Landfill, Public Hearing -Case Peter Beck, City Attorney No. LU 09-01 3.2. Request by Elk River Landfill, Inc. for Rezoning to change the zoning from Al (ME) Agricultural Conservation (Mineral Excavation) to AI (SWF), Agricultural Conservation (Solid Waste Facility), Public Hearing -Case No. ZC 09-01 Item to be discussed at a future meeting Request by Elk River Landfill, Inc. for Conditional Use Permit and License to expand the existing landfill into 109 acres of property located immediately south of the existin landfill, Public Hearin -Case No. CU 09-12 Introduction Staff and representatives from Elk River Landfill (ERL) presented at the June 9, 2009 Planning Commission of the ERL's request to amend the City's Comprehensive Plan and a Zone Change to expand their existing facility. The Planning Commission tabled this request to allow staff and ERL representatives time to meet to discuss the questions raised at the meeting and to analyze the information presented. Both parties met on Monday, June 15, 2009. Attached is additional information to assist the Planning Commission in its recommendation. Attachments ^ Memo dated June 18, 2009 from Lori Johnson, City Administrator ^ Supplemental Comprehensive Plan Information provided by Peter Beck, City Attorney ^ Memo dated June 16, 2009 from Brad Scheib, HKGi ^ Elk River Landfill Expansion Supplemental Information 16 June 2009 ^ Waste Management Letter re: Planning Commission Packet (distributed by ERL at June 9 Planning Commission meeting) ACtlon Motion by Second by Vote Follow Up S:\Council\Forms\Action Requested.doc - ~ •,^ // ~ .ver MEMORANDUM TO: Planning Commissioners CC: Mayor and Council Members FROM: Lori Johnson, City Administrator DATE: June 18, 2009 SUBJECT: Elk River Landfill, Inc. Request for Expansion -Follow-up to June 9, 2009, Planning Commission Meeting At the June 9, 2009, Planning Commission meeting both City staff and its consultants and representatives of the Elk River Landfill, Inc. (ERL) presented information on ERL's proposed expansion. ERL received the Planning Commission packet in advance and posed questions about the City's material at the meeting. City staff was not prepared to comment in detail on the information presented by ERL at the meeting as staff was hearing it for the first time along with the Commissioners. There are several items in ERL's presentation that require a response from the City. Those items along with the questions raised by ERL and planning commissioners are addressed by City Attorney Peter Beck in the document titled Comprehensive Plan, the memorandum and accompanying supplemental information from Brad Scheib of HKGi, and in this memo. Before responding to the questions submitted in writing by Waste Management, there are a few general comments on the action requested that are worth reviewing. First, the action currently before the Planning Commission, and ultimately the City Council, is whether to amend the Comprehensive Plan to change the land use on the proposed property. As the city attorney reaffirms in his response, a land use change is required in order to allow ERL's expansion into the 109 acre proposed development area known as the Southern Development Area (SDA). The question for the Commission and Council is this; does the City want the 109 acres in question to be a landfill or is some other type of development envisioned on that property? If the City wants the area to develop into a landfill, the Comprehensive Plan needs to be amended to change the land use because at the time it was adopted this property (the SDA) was not envisioned as a landfill. Second, in order to analyze the impact of this land use change, a long term approach must be taken as the property cannot easily or quickly be redeveloped in to a different use after it is used as a landfill. In doing the long term analysis there are some factors that are known, such as the fact that the land will carry a lower market value as a closed landfill than it would if it was a gravel mine or vacant property. Thus a closed landfill will also generate less tax revenue than the other uses. There are also some assumptions that need to be made to complete the analysis. The City has intentionally been conservative in its assumptions. Naturally, there are differences in the assumptions made by the City and ERL. The HKGi supplemental report identifies those differences in assumptions. Because the impact of the proposed land use change will be long term, the City's analysis extends well beyond the time frame used by ERL as we must assume if the landfill expands, it will remain a closed landfill beyond the 2050 timeframe used by ERL. The impacts of the land use change in this proposal are more dramatic as time passes. Third, several comments were made at the meeting about gravel mining development; however, as you know, .this item is not about gravel mining. It is about changing land use to accommodate a landfill. We assume that as long as the gravel in the SDA has more value than the property, it will be mined at the time the owner chooses. Conversely, if the property has more value than the gravel, the owner may choose to sell the property at any time without mining it. The same applies for the other gravel mining companies and property owners who have property in the gravel mining district. Similar to the gravel mining EIS process that was completed in 1994, the gravel mining area study the City intends to undertake in the future, possibly within a year, will include considerable participation by the gravel miners and property owners. Further, here is a response to the questions raised by ERL in Debra Walter's letter distributed at the planning commission meeting about the memo from Cathy Mehelich. The City has for many years identified the gravel mining area as a critical area for future development of both the jobs and tax base that are vital to the City's future. As we all know, the development of an area is affected by what surrounds it and the image it portrays. The City has identified image as an important factor in what types and quality of development will choose to locate in the City. Similar to other communities, Elk River wants to attract high quality development. This type of development demands an image that reflects the high values of the developer/company. When the Target store recently relocated to Otsego because the store could not physically expand on its existing site and no other large site was available in Elk River, the opportunity for a future store in northern Elk River was discussed by Target representatives. If that is to happen, it is important that the City position itself to fit the image that attracts that type of development. As to the question about timing of the expansion of urban services to the mining area, the timing has not changed. It has always been the City's position that the extension will occur when the property in the mining area is ready for development. Finally, the Planning Commission must make a recommendation to the City Council, based on the study of many factors including those presented by ERL, stating whether the commissioners believe the proposed landfill expansion merits a change in the Comprehensive Plan. The City Council will do the same when it decides if changing the land use to allow for the expansion meets its long term vision and goals of the City and is of benefit to its constituents. COMPREHENSIVE PLAN COMPREHENSIVE PLAN AMENDMENT The Applicant's Land Use Application sets forth their opinion that the proposed expansion does not require a land use change, relying in part on the fact that copies of the city's land use map which have been distributed to the public over the past few years have labeled the Tiller-owned Southern Development Area (SDA) as "Elk River Landfill". However, the Land Use Map in the city's 2004 Comprehensive Plan (figure 5-4), clearly designates the existing landfill as "Landfill" and the proposed SDA as "Mining". Changing the designation of the SDA from Mining to Landfill on the Land Use Map requires an amendment to the Comprehensive Plan. Such an amendment must follow the statutory process, including the affirmative vote of four members of the city council. No such amendment has been approved. Therefore, the land use designation of the SDA in the city's comprehensive plan remains "Mining". The fact that copies of the Land Use Map provided to the public incorrectly labeled the SDA as "Elk River Landfill" is of no effect. The Land Use Map cannot be amended through such a clerical error, but only through the statutory process required for a comprehensive plan amendment. Furthermore, the Draft EIS for the landfill expansion, upon which the applicant relies so heavily; clearly states that, "As part of this landfill expansion project, a request to expand the landfill designation to include the project site will be required." There is no question that the Comprehensive Plan must be amended through the process required by statute for expansion of the landfill to proceed. COMPREHENSIVE PLAN CONSISTENCY The merits of the proposed comprehensive plan amendment are a separate issue from the need for a comprehensive plan amendment. One of the issues for the Planning Commission and City Council to consider in weighing the merits of the proposed comprehensive plan amendment is the consistency of the proposed amendment (amending the Land Use Map to change the designation of the 109 acre SDA area from Mining to Landfill) with the balance of the Comprehensive Plan. The applicant has discussed at length in its application materials and presentations to the planning commission its arguments as to why the proposed expansion of the landfill is consistent with the city's Comprehensive Plan. The city staff has set forth its analysis of these arguments, the factors for the Planning Commission and the City Council to consider, and staff s concerns regarding consistency of the proposed expansion with the Comprehensive Plan. The Planning Commission should weigh all of this information carefully when considering whether to recommend that an amendment to the Comprehensive Plan to amend the Land Use Map be approved. The Planning Commission and City Council do not need to give any special weight to the findings or other statements set forth in the Environmental Impact Statement for the landfill expansion. The EIS was prepared by the landfill's consultant on behalf of the Minnesota Pollution Control Agency, which by state law is the Responsible Governmental Unit for landfill developments. The Draft EIS sets forth MPCA's opinion (as prepared by the landfill's consultant) regarding compatibility of the proposed expansion with existing and future land uses. These opinions, put forth in the Draft EIS before the City had an opportunity to formally comment on the EIS, are not binding on the City. The Elk River Planning Commission and City Council should consider all of the evidence before it, including the EIS, the materials submitted by the applicant and the materials prepared by City staff and the City's consultant planners, then make their own decision regarding the compatibility of the proposed landfill expansion with future proposed uses in this area of the City, the consistency of the proposed expansion with the City's adopted comprehensive plan, and the appropriateness of amending the Land Use Map element of the City's Comprehensive Plan to redesignate the SDA from Mining to Landfill. GP:2600181 vl ~ # v-~ ~ . 4 ~ a.: Hoisin ton Koe ler Grou Inc. ~ ~ _ "~" `~ g g p 4„f 4, ,,j ..~ r ' .l To: Lori Johnson, City Manager From: Brad Scheib, AICP Subject: Response to letter from WMI to Mayor Klinzing and the City Council regarding the Planning Commission Report for the June 9th PC Public Hearing. Date: 16 June 2009 This memorandum is a supplement to the June 9th Planning Commission report and a direct response to the questions raised by WMI related to the information from Hoisington Koegler Group Inc. A series of slides highlighting the key assumptions outlined in this report are attached. These slides also provide two graphs that highlight the long term impacts on property taxes and job development related to the expansion of the landfill. The slides are a summary of the information represented in this memorandum and the June 9th PC meeting report. Relationship to the Comprehensive Plan The comprehensive plan is a 20 year plan that envisions the gravel mining area being used for mining for the life of the plan (i. e. 2025). The comprehensive plan will ultimately be updated (probably multiple times) prior to development occurring in the project area. The ultimate end use for the SDA will not be mining or agriculture use. We evaluated potential land use impacts using the Highway 169 land use study as a basis for our land use assumptions. This study demonstrates a reasonable ultimate land use pattern within the Highway 169 corridor. A chart showing the land uses assumed for each scenario is included in the attached slides. Background Rationale for 2,000 foot peripheral impact area In understanding the impacts of the expansion, we evaluated two separate areas: the direct expansion area (SDA) and a peripheral area. Defining a peripheral area of impact was based on research of available online and hard copy resources held on file or obtained through MPCA. The findings were that there is not a specific uniform distance that defines an impact area but that a peripheral impact was more based on features unique to the site. Areas that sited various distances we referenced include: Monterey County, CA (Salinas Valley Solid Waste Authority); Florence County, SC; Sacramento County, CA (Kiefer Buffer Lands Land Use and Feasibility Analysis Final Report); Ontario, Canada; Northwest and Nunavut Territories, Canada (Residential Land Use Related to Landfill in Sites in Cold Region Communities); Eden Prairie, MN (Health Consultation for the Flying Cloud Landfill); Andover, MN (MPCA Land Use Plan); Hampton Township, M1V (MPCA Land Management Plan Dakhue Landfill); Inver Grove Heights, MN (Pine Bend Land Fill). We conducted visual analysis; however, we were limited to public right-of-way and did not enterprivateproperty. Furthermore, we did not have access to detailed contour data beyond the ERL or SDA site. It is our opinion that developing within approximately 2, 000 feet of a closed landfill will have an impact on what is developed and that impact will be related to the type of use proximate to the land fill. We recognize the distance selected has an impact on the results of the comparison. However, it does not impact the results of the analysis on the area of direct impact (SDA). We have provided slides that highlight the impacts ofjust the direct area and illustrate the various land uses assumed for existing conditions and future build out under each scenario. 123 North Third Street, Suite 100, Minneapolis, MN 55401-1659 Ph (612) 338-3800 Fx (612) 338-6838 www.hkgi.com Direct (612) 252-7122 Email bscheib@hkgi.com Supplemental Data on HKGi report 16 June 2009 Page 3 scenarios. Our assumptions are for development in the project area to be absorbed over a 10 to 25 year period at an annual absorption rate of 4%. This results in approximately 35, 000 to 90, 000 square feet of space per year from approximately 2030 to 2055. We did not address "indirect jobs "for either scenario due to the wide range of assumptions that might inform such an estimate. We recognize that while the landfill is operating there will be positive indirect economic impacts. When the landfill closes, those economic impacts will be greatly reduced. Development in place of the landfill expansion will continue to deliver positive indirect economic impacts well into the future. The landfill operations and gravel mining operations have a finite life. Once the resource is gone or capacity is used, those operations are closed and or reclaimed and indirect jobs related to gravel mining and landfill operations are gone. Projections and assumptions are speculative by their nature. Our projections are based on best available data and our firm's extensive experience in land use planning and community development. Due to the long term nature of this request and potential development, long term projections are necessary to fully understand the magnitude of this decision which will have short term benef is and long term consequences. We have prepared two graphs that best illustrate the potential fiscal impacts of the proposed landfill expansion showing the short term benefits and the longer term lost opportunity that development would bring to the area over time. These graphs represent potential property tax impacts and job growth impacts and are included in the attached slides. The land use fiscal impact and job growth analysis is only one part of what must inform a good decision on this expansion request. Elk River Landfill Expansion Supplemental Information 16 June 2009 In follow up to June PC Meeting and questions from WMI Hoisingtan Koegler Group Inc. Development Assumptions • Expanded landfill activities expected to be completed by 2033. • No urban development is assumed to occur until year 2030 at which time we assume a 4% annual absorption rate between 2030 and 2055. • End uses include open space, business park, highway business and light industry 1 Development Assumptions • Key land use assumptions - gravel mining from 2009 to 2021 - Landfill from 2010 to 2033 - SDA end use - 109 acres -Expansion of ERL • 8 acres Business Park (WMI uses 10 acres of highway commercial) • 101 acres Open Space (capped landfill and buffer) - SDA end use - 109 acres - No expansion of ERL • 45 acres open space (buffer area assumption proportionately consistent with peripheral area assumption) • 48 acres of business park • 16 acres of highway business Land Use Assumption Comparison (Expansion vs. No Expansion) SDA Expansion (Acres) SDA no Expansion (Acres) Open Space/Buffer 41 45 Business Park 8 48 Highway Business - 16 Closed Landfill 60 - Tota I 109 109 E ~ ~ ~ i Peripheral Area Expansion (Acres) Peripheral Area no Expansion (Acres) Open Space/Buffer 93 17 Residential 25 25 Business Park 31 86 Highway Business 25 55 Li ht Industrial 9 - Right of Way 18 18 Tota I 201 201 2 Development Assumptions • Key Fiscal Impact assumptions - City Land Fill Fee - $1 per cubic yard ($13.6 million in fees, assuming capacity of expansion is met by 2033) - Gravel mining fees assumed to be the same under both scenarios -for comparison purposes it is neutral. - Land value for mining - $0.26/sq. ft. - Land value for landfill - $0.53/sq. ft. - Scenario 1 (expansion of land fill) • build out of Business Park in 10 years (2031 to 2041) • build out of peripheral area in 25 years (2031 to 2056) Development Assumptions • Key Fiscal Impact assumptions (continued) - Scenario 2 (no expansion of land fill) • build out of Highway Business in 25 years (2031 to 2056) • build out of peripheral area in 25 years (2031 to 2056) - Property Tax Assumptions • Highway business - $21,437 per acre (Wal-Mart, M&I Bank, Carson Bus Park Strip Mall) • Business park - $30,162 per acre (Hillside Crossing South, Target Data Center, United Health Group) • Light Industry - $17,201 per acre (North Star Business Park) - Factors inflation at 2% per year 3 Adjustments to Model • We have made two minor adjustments to the model based on further analysis. - 1 -- we have adjusted the acres under the SDA expansion scenario for commercial development from 8 acres to 10 acres. - 2 -- we have adjusted the assumption about square feet per employee from 350 square feet to 500 square feet for business campus land use. 4 $e~ooo~ooo I~- $7.000,000 4•-. $6, 000, 000 $5,000,000 --- m $4,000,000 " 0 o $3,ooaooo $z,ooo,ooo '_ $1,000,000 ''~, $_ L zolo 1,800 1,600 1,400 .. 1,200 0 1,000 c C 600 0 a a ~ 600 __ 2010 2020 2030 2040 2050 2060 2070 2080 Time -Total Jobs (Scenario 1 Expansion) -Total Jobs (Scenario 2 no expansion) 1 2020 2030 2040 2050 2060 2070 2080 Year -Prop Tax (Scenario 1 expansion) -Prop Tax (Scenario 2 no expansion) -Host Fee (City and County Total) -Host Fee (City Only) Key Differences in Assumptions • Land Uses (8 acres of business park use by HKGi vs. 10 acres of highway commercial by WMI) • 2,000' peripheral area included in HKGi analysis, not in WMI • Inflation of 2% assumed by HKGi--no inflation assumed by WMI • Gravel mining fees assumed to be neutral by HKGi--WMI factored in Gravel Mining fees • HKGi projected development to 2080 vs. 2050 projected by WMI WASTE MANAGEMENT Mayor Klinzing and Council Members Chair and members of Planning Commission C/O Lori Johnson, City Administrator 13065 Orono Parkway Elk River, MN 55330 RE: Planning Commission Packet Dear Major, Council Members, Commission and Staff, ELK RIPER LQNDEILL Elk River Landfill, Inc. 22460 Hwy. 169 NW Elk River, MN 55330 (763)441-2464 (763) 441-2025 Fax We have been making a concerted effort to work cooperatively with you in the preparation and processing of our applications associated with the landfill expansion. We have met with staff and the city attorney and quickly responded to all of the additional information that they requested. We were therefore very disappointed to receive the Planning Commission packet at 4:15 pm last Friday afternoon. More importantly, we were surprised to find the Hoisington Koegler report and other documents introducing new issues and concerns. Because we received this information so late, we were not able to adequately respond in time for the planning commission meeting. We respectfully request answers to the following questions as soon as possible and certainly no later than Thursday, June 1 1, if this item is to be scheduled for the June 15 City Council Meeting. The Elk River Landfill received the following two reports on June 5, 2009 regarding the impact of our land use application: • Impact of Elk River Landfill Proposed Expansion on City's Image and Marketing Efforts -Catherine Mehelich, Director of Economic Development • Landfill Expansion Impacts -Brad Scheib, AICP, HKGi We have reviewed the reports and have the following questions regarding the materials presented in these two documents. Impact of Elk River Landfill Proposed Expansion on City's Image and Marketing Efforts - Catherine Mehelich, Director of Economic Development Questions regarding Ms. Mehelich's memo: • Did the Economic Development Strategic Plan suggest a dramatic change in the existing comprehensive plan that directs this type of development (professional services, corporate campuses, energy-related and technology businesses) to be located in the existing core? From everyday collection to environmental protection, Think Green® Think Waste Management. ® Pnn[ed on ]00°k post~conrumei reryded paper. • Did the Economic Development Strategic Plan propose to extend urban services into the mining area sooner than planned? • How would attracting another retail store accomplish any of the strategic objectives noted in the Economic Development Plan? • Didn't a Target Store go out of business approximately three miles further south, much closer to more Elk River households? • Did you actually discuss the landfill expansion with Target, or are you speculating on their response? • Is it your opinion that the expansion of the ERL at the extreme northern edge of Elk River, would adversely affect the City's ability to successfully implement the comprehensive plan's stated goal of concentrating development in close proximity to the downtown? • Has the presence of the existing landfill impeded the extensive commercial development three miles south of the SDA? Landfill Expansion Impacts -Brad Scheib, AICP, HKGi Questions regarding Mr. Scheib's memo: • Have you been asked to assume major and fundamental amendments to the existing comprehensive plan, like the timing of urbanization of the Mining Area? • What studies are you referring to when you discuss peripheral impacts and how can we get them to evaluate their applicability? • Why would you rely on a 2,000 ft buffer dimension based on generally applicable view conditions when there is extensive specific visual analysis available, including your own? You do recognize that if the actual area of peripheral impact is 1,000 ft. or 0 feet in dramatically changes your conclusions about the ultimate fiscal impact 70 years from now. • The proposed project will result in generation of approximately 6 megawatts of green power. The existence of a reliable green power source has proven to be a strong economic development incentive. The USEPA has documented over 450 such projects. Where you aware of this fact, and if so, why was it not included in your study? • Since green power has been demonstrated to be a strong economic development engine, wouldn't it be reasonable to assume that businesses would prefer to locate within 2,000 feet of the SDA? • If your analysis was limited to lands located within the City of Elk River, where do the conditions exist to support your assumptions regarding development within peripheral impact areas? • Are your assumptions regarding the mixture of businesses, number and types of jobs in your direct and peripheral impact areas based on the studies you referred to or real world examples? If it is real examples, please identify them so we can complete our own analysis. • Tiller Corporation owns the land under the SDA. Without the SDA, they have testified before the city council and met with the city staff to inform the city that mining won't start for 30 - 40 years. They estimate the soonest the land will be available for reuse is 2070. The 2004 Comprehensive Plan assigns no urban development in the Mining Area until post 2030. Given these facts, how can you conclude that your predicted loss of tax revenues starts in 2009? • One of your key assumptions under the no expansion scenario is that the gravel mining area will be gradually reclaimed "as extraction is completed and reuse occurs". You state that this transition will start in 2012.Have you asked Tiller about these assumption? Just for instance, The Maple Grove Gravel Mining Area was mined for 25 years before 1/3 of the area was available for the development of Arbor Lakes. • Have you calculated all of the direct and indirect jobs associated with the SDA? • Is a $1 million dollar annual payroll over 37 years "short term jobs''? • Are you aware of the numerous advances that are being made every year in waste to energy technology? • If technology were to emerge between now and 2080 that would allow the vast supply of waste stored at ERL to be converted into a clean, cost effective alternative energy source, do you think that might change the business location decisions for alternative energy, technology based businesses? • If that happened 10 years from now, how would it change your projections? 20 years? 30 years? 40 years? 70 years? • The Metropolitan Council makes 20-year forecasts for household and employment growth every 10 years. Based on numerous generalized assumptions you are making fiscal impact projections over 70 years into the future. Are you really suggesting that these projections are accurate and the City of Elk River should rely on them in making a decision of this magnitude? Sincerely, Elk River Landfill, Inc. Debra Walters District Manager c: John Shardlow, Bonestroo John Kellas, Waste Management Gary Sauer, Tiller Corporation ~TT[il iTi i~ ^ ~~ ~~~ ~~ ^ i I!~"iTi • l • • i^: - ~_~~ ~,' ~-' .~ ~ ~- ~~ ~ , • 11YAST~ Rdl1lill~t~E~Y101LT ~r ,~ _~~ ~~ - ~,' N~~nav~~t C'_anarla ~{ Property Owners That Spoke at Last Meeting ~~ .~ - ~ Y ~1 I ~ j[~~~ •~ 4 1~ r n T u < 1 ~ ~ i - i®e fi ~ ' H o ~ ~; ~ rY ~~~. f ~~ ,~ - , . .m. ~~ n '' "~ ~ ~~- ~~ ~,~: ~. ~i ~, ~ ~, ~ ~ ~ ~.~ ~ pY ~ ~ ,, ~ - .. p ~ i E. h~~ ` .., _ ~~ ,~a. , - ;. ~~ r, - ~~, .~ Y ~, ~,_ -~~~ i ~" ~ "~ A ~ b' y ~. ~ ,,9 ~ - ~ ~ ~~~ .p ~. ~ ~ ~ ~~I Y f~~'i ^J ` palit ~ ~ i~ ~~~~^ fA~l ~ i i~~ R' ~~~ u v .~ - ~~ - nJ~r. ~, - _ ~ _ ' . w ~ 0 ~~ ~ ~ ~~ ~ ~ A ~ ~.n ~ d~~ ~~, 9 ~ _ ~ fi'~ _ i ,,, m ~ ~w :r a ~. -~ ~ ~- ~ ,. ~~ ~ w - ~ ~ M ~ ~ ~ ~ C I ~ ..~ L" :, ~ III I m~~ ~I~ . 1 z: 4 - ~,~ ' ~~ ~_ r :~~~ ~s y ~ m ~~ __ ~ ~ v ~. i Y ~ w ~ (i ~ ~ p. .: ' '~1 Iii t3 ~i n_ (iI~ z ~' 1 ~„I a ~ ~ ~ ~= a n' ~:.~, F~ •'' ~ ~° ~ . ~~, ~. r ~ _ ~ ~- ~ ~' ~ _, `: ~, ~: ~ ~' ~` ~„"'~ '~ ~~ ~~ ~ ,~+~ ~ t ,~ ~ ~~ ~, u~ ~ ~~° ~ ~.~~ r m R ~ t 1 f ~ ~~ :, L °~ ~'~ ~~ ~ ~~ '°~~~~ ~, ~~, ~ d ~ ~# ~ - ~~ ~ ~~ a ~~~ ~• ~~^ ~ ~- ~ a ~ <a - ~, I`. tl ~ Y 6] ~ ~^~ ~,,, ~ ~-~~~ _ ~~ - m ti fi ~~ i I _ ~4 ~- - .. ~~~~ ~~ ,~ ~; F ~. . ~` _~~ ~ _ ~~ ~. _ , Bonestroo Elk~~ Y Comprehensive Plan R],VeY Building the Future of Elk River f ~ ,, i ~ -i - 310 I to ~a~~ ~ :~ _ - 4 ~ ~- ~~'I i -I g ~~' I i„ Y S ~~~ ~` -~ 1 A ,,~ e ., a P ,.~„~^~` . ~, -~. ry ®© Hor>iagton Kneeler ~*~~up I;r~. ~~ ,* , ~~ ~ ~. iii ~ ~ _ . ~ 1111 I ~, ~ >,. w,. k~ " ~ '19 ~ tee.. .: y,.•y Elk~~ Y Comprehensive Plan R],VeY Building the Future of Elk River f ~ ,, i ~ -i - 310 I to ~a~~ ~ :~ _ - 4 ~ ~- ~~'I i -I g ~~' I i„ Y S ~~~ ~` -~ 1 A ,,~ e ., a P ,.~„~^~` . ~, -~. ry ®© Hor>iagton Kneeler ~*~~up I;r~. ~~ ,* , ~~ ~ ~. iii ~ ~ _ . ~ 1111 I ~, ~ >,. w,. k~ " ~ '19 ~ tee.. .: y,.•y Elk River Landfill Expansion FINAL ENVIRONMENTAL IMPACT STATEMENT JANUARY 2~D5 ~1inn~~t~ ~~~I~#ic~n ~n~~+~l ~n ~ Y '+F 52(~ L~f~y~+#t~ far Narih, fit. 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