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G-2. Adoption of Update for Alternative Urban Areawide Review for Avienda e, CITY OF CIIANIIASSEN � sv N S Chanhassen isa Community for Life-Providing for Today and Planning for Tomorrow MEMORANDUM TO: Todd Gerhardt, City Manager FROM: Kate Aanenson AICP, Community Development Director DATE: May 8, 2017 SUBJ: AUAR Final Adoption and Mitigation Plan ACTION REQUIRED City Council approval of the"Resolution Adopting a Final Alternative Urban Areawide Review (AUAR) and Mitigation Plan for the 2005 Metropolitan Urban Services (MUSA)" * requires a simple majority of City Council present. EXECUTIVE SUMMARY This is the final action required for the adoption of the Update to the 2005 MUSA AUAR. Attached are the: • AUAR Update Process Steps (Minnesota RULES 4410.3610 Subpart 7) • Resolution Adopting a final Updated AUAR • Comments Received • Response to the Comments Received • Proposed Mitigation Initiatives PUBLIC COMMENT • February 27, 2017 during its Work Session the City Council reviewed the significant issues of the AUAR. • February 28, 2017 an Open House was held. • March 7, 2017 The Planning Commission held a public meeting on to review the proposed updated to the document. The Planning Commission forwarded their comments to the City Council. • March 13, 2017 the City Council authorized publication in the EQB Monitor for April 3rd and closing the comment period on April 17th PH 952.227.1100• www.ci.chanhassen.mn.us • FX 952.227.1110 7700 MARKET BOULEVARD • PO BOX 147 • CHANHASSEN • MINNESOTA 55317 Todd Gerhardt AUAR Final Adoption and Mitigation Plan May 8, 2017 Page 2 of 2 RECOMMENDATION Staff recommends adoption of the attached resolution. ATTACHMENTS 1. AUAR Update Process Steps 2. Resolution Adopting an Updated AUAR&Mitigation Plan 3. AUAR Comments 4. AUAR Responses to Comments 5. Updated AUAR g:\plan\2016 plaiming cases\2016-25 avienda\auar\cc approval of auar updae.docx 0,Es(il9 2 EQB o Quick Reference: Alternative Urban Areawide Review 4iF4',AL 00- AUAR Update Process Steps (Minnesota Rules 4410.3610 Subpart 7) Minnesota Rules provide guidance on the circumstances that require an AUAR update. Regardless of any significant changes, the AUAR must be updated every five years until all of the development in the area has been approved. An AUAR update is generally a faster process than starting a new AUAR since the update process does not require a complete revision of the AUAR doctunent. Instead,the update process requires that the AUAR document,along with the mitigation plan, be updated to the extent necessary to reflect the changes that have occurred in the area included in the review. The updated documents are distributed in a manner similar to a final AUAR except that the documents must be sent to all parties listed on the EAW distribution list and a notice must be published in the EQB Monitor. The process for appeal to the EQB can still be invoked by state agencies and the Metropolitan Council as in the normal AUAR process. 1 Reviewers have 10 /RGU distributes AUAR days from publication draft and mitigation date in EQB Monitor RGU completes a draftg update of the AUAR and plan update for to submit written mitigation plan > comments.Notice is > conunents to RGU. (4410.3610 Subp. 5 D-H published in the EQB State Agencies and the & Subp. 7) Monitor Met Council have 10 1 (4410.3610 Subp.S D days from receipt of zy\,.... & Subp. 7) jfinal AUAR documents to file an objection (4410.3610 Subp. 5 D)1 5 O G 0 c •c RGU adopts final V AUAR and mitigation Negotiations between RGU plan.Notice is Resolved and objecting agency published in the EQB (4410.3610 Subp. 5 F&G) Monitor ` (4410.3610 Subp. 5 E)J7c) z 9v, o ° 2 V EQB action required Inadequate to determine adequacy of AUAR documents (4410.3610 Subp. 5 H) J Updated December 2015 Page 3 CITY OF CHANHASSEN CARVER AND HENNEPIN COUNTIES,MINNESOTA DATE: May 8,2017 RESOLUTION NO: 2017- MOTION BY: SECONDED BY: RESOLUTION ADOPTING A FINAL UPDATED ALTERNATIVE URBAN AREAWIDE REVIEW (AUAR) AND MITIGATION PLAN FOR THE 2005 METROPOLITAN URBAN SERVICES AREA(MUSA) WHEREAS, on November 28, 2016,the City of Chanhassen, acting as the official Responsible Governmental Unit(RGU), approved Resolution 2016-85, an Order for Updating the Alternative Urban Area Wide REVIEW(AUAR) for the 2005 MUSA; and, WHEREAS, on February 28, 2017, the City of Chanhassen held an Open house to review the Update of the AUAR environmental analysis document; and, WHEREAS, on March 7, 2017,the City of Chanhassen Planning Commission reviewed the Update to the AUAR environmental analysis document; and Notice of Availability of the Update to AUAR environmental analysis document was made know; and, WHEREAS,the April 3, 2017,the Update to the AUAR environmental analysis document and Mitigation Plan was distributed in accordance with Minnesota Environmental Quality Board Environmental Review Program procedures and published in the EQB Monitor on April 3rd, 2017 for review and comment; and, WHEREAS,upon completion of the 10 day review period, as prescribed by Minnesota Rules, ending April 17, 2017, an updated AUAR environmental analysis document and Mitigation Plan was prepared based on comments received; and, WHEREAS, the City of Chanhassen, distributed the revised AUAR environmental analysis document and Mitigation Plan for the 2005 MUSA in accordance with Minnesota Environmental Quality Board Environmental Review Program procedures; and, WHEREAS,no objections to the revised AUAR environmental analysis document and Mitigation Plan were filed with the City of Chanhassen within the 10 day objection period as prescribed by Minnesota Rules. WHEREAS, on May 8,2017,the City of Chanhassen reviewed a Final AUAR Environmental Analysis Document and Mitigation Plan for the 2005 MUSA NOW, THEREFORE, BE IT RESOLVED that the City of Chanhassen hereby adopts the Update to the AUAR environmental analysis document and Mitigation Plan for the 2005 MUSA. Passed and adopted by the City Council of the City of Chanhassen, Minnesota, this 8th day of May, 2017. ATTEST: Todd Gerhardt,City Manager Denny Laufenburger,Mayor YES NO ABSENT Chanhassen 2005 Alternative Urban Areawide Review 2016 Update MITIGATION INITIATIVES Mitigation Plan. The final AUAR document must include an explicit mitigation plan. At the RGU's option, a draft plan may be include in the draft AUAR document;of course, whether or not there is a separate item for a draft mitigation plan, proposed mitigation must be addressed through the document. It must be understood that the mitigation plan in the final document takes on the nature of a commitment by the RGU to prevent potentially significant impacts from occurring from specific projects. It is more than just a list of ways to reduce impacts—it must include information about how the mitigation will be applied and assurance that it will. Otherwise, the AUAR may not be adequate and/or specific projects may lose their exemption from the individual review. The RGU's final action on the AUAR must specifically adopt the mitigation plan; therefore, the plan has a `political"as well as a technical dimension. This Mitigation Plan identifies initiatives that address potential impacts resulting from future development within the AUAR Project area. This mitigation plan specifies the controls, procedures, and other steps that may be implemented to protect or minimize potential negative impacts. In order to mitigate the potential environmental impacts identified in the Chanhassen AUAR, The City of Chanhassen will commit to implementing the mitigation initiatives identified in this plan. Intent of Mitigation Plan New development generates impacts on the environment and on existing development.These impacts result from construction activities associated with new development(i.e. erosion, dust, noise)as well as post construction associated with the activities and design of the development (i.e.traffic, runoff, pollution, infrastructure demand). This plan identifies existing tools and policies that the City of Chanhassen has in place to address the types of impacts that may result through development of the Chanhassen AUAR project area. The plan also identifies additional initiatives that will need to be implemented to mitigate potential environmental impacts resulting from projected development of the project area. There are multiple ways in which Mitigation Initiatives may be implemented such as: o Enforcing existing zoning and subdivision ordinances and other development regulations at the time of development concept submittals, preliminary and final platting, and during construction monitoring activities; o Referencing and implementing policy directions during the review and approvals of development projects; o Facilitating additional study as regional transportation planning initiatives become more finalized or as other regional developments alter travel patterns/behaviors. o Planning and building public infrastructure(local roads, parks,trunk sewer systems and water systems)in conjunction with private development initiatives; o Maintaining and updating of existing plans and studies for the community; o Requiring additional field work/investigations as part of pre development planning where potential environmental or cultural resources may exist but have not been verified. Page 42 Chanhassen 2005 Alternative Urban Areawide Review 2016 Update General Mitigation Initiatives This section identifies a series of mitigation initiatives that are general in nature and apply to all public and private development within the AUAR. 1. All permits identified in the AUAR(See question#8)as well as other necessary permits that may be required will be secured by the City,or private parties as appropriate,for all development activities within the project area. 2. The City will follow its own regulations, ordinances, plans, and policies currently in place in the review and approval of all development activities within the project area. These items include The 2030 Comprehensive Land Use Plan, the official zoning and subdivision ordinances and the Bluff Creek Overlay ordinance. In addition,the Bluff Creek Watershed Natural Resource Management Plan, the Surface Water Management Plan, the Comprehensive Water Supply Plan, and the Comprehensive Sanitary Sewer System Plan will be used as technical resources in reviewing development activities and developing associated public infrastructure. 3. The City will extend public sewer and water services in a manner consistent with existing plans and policies for delivering trunk sanitary sewer service and water main systems. Abandonment and closure of individual well and septic systems will follow existing local and state regulations. 4. The City will work with Mn/DOT and Carver County to periodically monitor traffic as generated from development within the project area as well as regional development initiatives that will affect the project area. Performing traffic counts and monitoring traffic movements will help in facilitating future local roadway improvements. 5. The City will provide for adequate regional and local stormwater ponds and trunk facilities to protect water resources and water quality as guided by the Surface Water Management Plan and the Bluff Creek Watershed Natural Resource Management Plan. 6. The City will to monitor development within the AUAR Project Area and its conformance with the development scenarios assumed in the AUAR. 7. The City will enforce its parkland dedication practices consistent with the goals and policies outlined in the 2030 Comprehensive Plan and the Bluff Creek Watershed Natural Resource Management Plan and the requirements of the subdivision ordinance. 8. The City will follow existing zoning regulations including Floodplain Overlay(Article V), Wetland Protection(Article VI), Shoreland Management(Article VII), Bluff Protection(Article XXVIII)and Bluff Creek Overlay(Article XXXI)to protect natural and environmental resources from potential impacts resulting from the Development Scenario. The City will reference policies and strategies outlined in the 2030 Comprehensive Plan, Surface Water Management Plan and the Bluff Creek Watershed Natural Resource Management Plan as technical resources during the review of specific development projects. Focused Mitigation Initiatives Mitigation initiatives that are explicitly intended to mitigate or minimize impacts on a particular resource or action are outlined by topic in this section. Fish, Wildlife and Ecologically Sensitive Resources The Bluff Creek Overlay zoning ordinance contains provisions that require a detailed analysis of habitat conditions prior to development. This analysis is provided as part of the preparation of development plans. Staff will verify the findings of the work and will work with developers to design projects in a manner that protects and preserves these habitat areas. Implementation of the Bluff Creek Overlay zoning ordinance will protect resources within the Bluff Creek corridor (See Figure 4 Significant Habitat Areas of the AUAR Document.) Page 43 Chanhassen 2005 Alternative Urban Areawide Review 2016 Update Other areas within the project area maintain significant wildlife or ecologically sensitive resources. The most prominent resources are identified in Figure 4.The identification of these areas provides advance notice to developers to plan developments in a manner that protects their ecological function.The City's 2030 Comprehensive Plan, the Bluff Creek Watershed Natural Resources Management Plan,the Bluff Creek Overlay zoning ordinance and the Planned Unit Development(PUD)zoning mechanism (Article VIII)provide the City with the necessary tools to be flexible with subdivision design in order to preserve these areas.A cooperative approach to planning and design will be implemented to protect other wildlife and sensitive resources. In addition to implementing existing plans, policies and regulations,the City will actively work with non-profit groups focused on preserving quality open spaces and environmental resources that are identified with this AUAR and future more detailed development planning initiatives. While there are no instances of high biodiversity or ecological significance directly within the project area,there are sensitive areas surrounding the site(primarily south of the site and south of Highway 212)that should be protected from indirect effects(as shown in Figure 5). Initiatives being implemented within the development area in pursuance with the Bluff Creek Overlay zoning ordinance are established to prevent or mitigate potential impacts to surrounding environmentally sensitive sites. In addition, best management practices for site design and storm water management will be encouraged through the site planning and planned unit development process. Water Resources(wetlands, creeks, lakes) and Surface Water Management Increased stormwater runoff will result from future development in the project area. The Surface Water Management Plan and watershed regulations establish standards for surface water runoff. Key policy directives relative to the protection of water resources and the management of surface water runoff include: • Abstracting the first 1.1-inch of runoff from new impervious surfaces. • Maintaining peak discharge rates at or below current levels. • Providing water quality treatment of runoff prior to discharge from the site or into onsite wetlands. • Conform to NURP standards. • Remove 60% of phosphorous and 90% of total suspended solids on an annual basis. • Discharge to Lake Susan shall not impair water quality. • Discharge to Bluff Creek shall improve water quality. • Providing pre-treatment for infiltration or filtration practices. • Developing storm water quality and quantity treatment by site or development. • Preparing a Storm Water Pollution Prevention Plan(SWPPP)for each development or site. • Conformance to NPDES Phase II requirements as outlined in the EPA Clean Water Act. Additional strategies and policies that direct development in a manner that minimizes impervious surface coverage are outlined in the 2030 Comprehensive Plan, The Bluff Creek Watershed Natural Resource Management Plan, the Wetland Conservation Act and the City's Wetland Protection Ordinance. Projects within the AUAR that impact wetlands will be subject to regulation under the City of Chanhassen Wetland Ordinance,Wetland Conservation Act, Chapter 103G Waters of the State (i.e. Department of Natural Resources), and possibly Section 404 of the Clean Water Act(i.e.the U. S. Army Corps of Engineers). Should wetland impacts be part of a project within the AUAR these regulatory programs have sequencing requirements which require applicants to demonstrate that wetland impacts have been avoided and minimized to the extent practicable and if impacts cannot be avoided these programs require replacement of wetlands impacted by fill or excavation. Page 44 Chanhassen 2005 Alternative Urban Areawide Review 2016 Update Erosion and Sedimentation The City of Chanhassen utilizes"Best Management Practices"as outlined in various resources and by the Metropolitan Pollution Control Agency(MPCA). During construction activities and prior to the maturing of vegetative cover over disturbed ground, proper techniques will be used to control erosion and sedimentation. The City's existing code provides the regulatory tools for this initiative. Land use management and zoning tools(PUD, density transfers, Bluff Creek Overlay) will be implemented to direct development to less erosion prone areas of the site. Wastewater The development scenarios identified in this AUAR are consistent with the City of Chanhassen 2030 Comprehensive Sanitary Sewer System Plan. The City of Chanhassen through its site development plan review process will monitor and verify estimated wastewater flows for general conformance to the Plan. In addition, each development will be responsible for the following: • Conformance to the City of Chanhassen Comprehensive Sanitary Sewer System Plan. • Metropolitan Council Environmental Services(MCES)Sanitary Sewer Extension Permit(s) • Sewer Access Charges(SAC)related to their proposed development. • The proportional share of the costs of Trunk Sanitary Sewer Mains. • Construction of local sewer mains to serve the development. Water Supply Public water supply has been provided to the study area by the extension of trunk water lines. The Avienda project will need to install a 12-inch trunk water line from the existing end of Bluff Creek Boulevard to Powers Boulevard to complete the trunk system. These trunk water lines will supply water to the development area through a local system of water lines to be constructed as development occurs. Each development will be responsible for the following: • Conformance to the City of Chanhassen Comprehensive Water Supply Plan. • Minnesota Department of Health permit(s)for the extension of water supply systems. • Water Access Charges(WAC)related to their development. • The proportional share of the costs of Trunk Water Supply lines. • Construction of local water supply lines to serve the development. Traffic/Transportation Mitigation Initiatives There are a number of specific traffic/transportation initiatives already constructed to adequately address potential development impacts. As discussed in the AUAR Question 21-Traffic and Appendix 5-Traffic Analysis,the mitigation approaches outlined below depend on the remaining AUAR development growth.. 1. Proposed improvements to accommodate the remaining AUAR development traffic include the following: a. With the improvements already constructed, the TH 212 interchange at the east end of the AUAR Development will be able to accommodate project traffic at acceptable levels of service. b. Improvements to Audubon Road include adding left-turn lanes on the northbound and southbound (Audubon Road)approaches to the intersection with Lakeview Drive. c. Based on the capacity analysis for Scenario F-2 and F-3,the following intersections should be monitored for potential signalization (if volumes warrants are met)as the area develops: a) Lyman Boulevard&Audubon Road North/NW Quadrant Access b) Lyman Boulevard &Sunset Trail/NE Quadrant Access c) Powers Boulevard & Pioneer Trail Page 45 Chanhassen 2005 Alternative Urban Areawide Review 2016 Update 3. When plans for reconstruction of existing roads or construction of new roads are developed, incorporate design considerations that will mitigate noise impacts.These design considerations would include landscaping, berming and speed limit controls. 4. Coordinate development of perimeter road connections(such as where a collector roadway within the project area connects to Audubon, Lyman or Pioneer Trail)with Carver County, the City of Chaska and adjacent neighborhoods. 5. Ensure subdivisions include plans for Pedestrian and Bicycle movement in and through the project area as well as linkages to the greater community. Roadway designs will meet the City's current design standards for on-street and off-street trail connections. The City will work with Carver County to preserve Right-of-Way(ROW)for off road trails. Land Use Management Initiatives The project area is unique because of its topographical features and the Bluff Creek corridor. This uniqueness poses challenges to development. Efforts to minimize impacts on the Bluff Creek corridor and to maintain as much of the pristine environmental presence of the site will have to come from combined public and private actions.The City of Chanhassen is well positioned from a regulatory position to guide development in a manner that achieves the objectives of the 2030 Comprehensive Plan and Bluff Creek Watershed Natural Resource Management Plan. Specific strategies that enable the City to achieve these objectives include: o Transfer of density—this approach to development would enable a developer to move units within a development project from areas that are desired to be preserved to areas that are less sensitive.The developer would not loose density in the project by interjecting a broader mix of units and lot sizes. o Clustering of housing units—this is a conservation development approach used to minimize development impacts on adjacent resource areas. Although it is more widely used in rural developments, it can be used in urban settings to obtain the same resource protection results. Clustering in an urban setting will also reduce infrastructure thereby reducing up front and longer term maintenance costs. In general terms, clustering requires smaller lot sizes, reduced street widths to balance increased protection areas.This would likely be used in conjunction with a transfer of density when properties have environmental protection areas and involve a Planned Unit Development(PUD)process. As the project area develops,there will be a need for park improvements. The City will use its existing park dedication policies to help fund these improvements. Monitoring of Development in the AUAR Area and Future Updates to the AUAR The AUAR assumes a hypothetical development scenario. Because it is based on assumptions, it is important that actual development be monitored and compared to the development that was assumed in the development scenario.Tracking of this development will be done through the City's existing GIS system. The developer as part of the final plat process will submit electronic plats consistent with city development requirements in a compatible form to the City's GIS system. This data will enable the City to maintain an ongoing inventory of platted lots and the ability to directly tie building permits to the lots so that occupied housing units could be tracked in the development area. The City's existing GIS system has the capacity to perform this task. As required by Minnesota Rule 4410.3610 Subpart 7, to remain valid,the AUAR must be updated if any of the following events should occur: o Five years have passed since the AUAR and mitigation plan were adopted and all development within the project area has not been given final approval. Page 46 Chanhassen 2005 Alternative Urban Areawide Review 2016 Update o A comprehensive plan amendment is proposed that would allow an increase in development than what was assumed in the development scenario. o Total development within the area would exceed the maximum levels assumed in the environmental analysis document. o Development within any subarea delineated in the AUAR would exceed the maximum levels assumed for that subarea in the document or is of a different land use type. o A substantial change is proposed in public facilities intended to service development in the area that may result in increased adverse impacts on the environment. o Development or construction of public facilities will occur differently than assumed in the development scenario such that it will postpone or alter mitigation plans or increase the development magnitude. o New information demonstrates that important assumptions or background conditions used in the analysis presented in the AUAR are substantially in error and that environmental impacts have consequently been substantially underestimated. o The RGU determines that other substantial changes have occurred that may affect the potential for, or magnitude of, adverse environmental impacts. Page 47 MEMORANDUM Hoisington Koegler Group Inc. ©© ©8 To: Kate Aanenson From: Brad Scheib Subject: Response to Comments Received on the AUAR Date: 26 April 2017 The draft AUAR update was distributed to agencies and requesting parties the week of March 27,2017. Notice of the draft available for review was published in the EQB Monitor on April 3rd, 2017.Comments on the AUAR were accepted through April 17,2017.Comments were received from the following entities(and are attached to this memo): 1. Landform 2. Carver County 3. Minnesota Department of Transportation 4. Department of Natural Resources 5. Riley Purgatory Bluff Creek Watershed District 6. Minnesota Pollution Control Agency 7. Metropolitan Council 8. Residents at the"Preserve at Bluff Creek" The following represents that responses to the comments received.Generally responses are in italics. Landform: Letter included 9 comments addressed as follows: 1. Text was modified in this section to indicate: "Where essential services are needed in this area, low impact development techniques should be used to minimize development impacts." 2. Typo corrected 3. No response required. 4. References to Wetlands B and C referred to the original delineation performed on the Town and Country site.Because this area has since developed,reference to wetlands B and C have been deleted. 5. The wetland section incorrectly states that 10 wetlands drain to Bluff Creek. The AUAR will be updated to reflect that wetlands 3,4,5, 6 and 10 on the Avienda parcel drain to Bluff Creek and wetlands 1,2, 7, 8, and 9 drain to Lake Susan. 6. No changes made.Required review of habitat conditions depends on the site, available background data, and intended uses.As such,level of analysis might vary and is determined at time of application. 7. No changes made.Land use consistency with the AUAR will be an interpretation made by the City at the time of development application. The mix of uses anticipated in the AUAR may vary from the actual development. The actual development will be evaluated based on the total magnitude and maximum levels of impacts assessed in the AUAR. If the development project exceeds these impacts, an update to the AUAR(or an EAW)could be required. 8. Figure 14A was modified to show land uses where wetlands are proposed to be filled and mitigated. 123 North Third Street,Suite 100,Minneapolis,MN 55401-1659 Ph(612)338-0800 Fx(612)338-6838 www.hkgi.com Direct(612)252-7122 Email brad@hkgi.com AUAR Update Comments and Responses 26 April 2017 Page 2 9. The development is proposed to construct Bluff Creek Boulevard as a two-lane divided roadway,which means the northbound left-turn movement and westbound through movement at TH 212&Powers Boulevard would need to be reduced to one lane each.During the development approval process, the Developer should provide the City with intersection analyses information so that it can be verified whether a two-lane section for Bluff Creek Boulevard is acceptable. The viability of the phasing of a second lane on Bluff Creek Boulevard to accommodate future traffic growth also needs to be studied further. MnDOT and Carver County will need to be included in this evaluation as the proposed changes will impact roadways under their jurisdiction. Carver County: The County is requesting that additional reports and figures be provided detailing proposed roadway,traffic, stormwater,parks and trails,and utility infrastructure included as a part of the development. It is also noted that any work affecting County highways will need to be permitted by the County. The requested information will be provided to County staff as the infrastructure details are further developed during the development review process. Minnesota Department of Transportation: Letter is informative and requires no changes to the AUAR Department of Natural Resources: Letter points out that NHIS(Natural Heritage Information System)reviews are valid for one year and reliance on former work conducted and work conducted for other projects is not recommended or may not be appropriate to satisfy the AUAR review. Further review was recommended and conducted relative to the Minnesota Natural Heritage and Nongame Research Program.A one mile radius of the project area was reviewed by the DNR and no new known occurrences of rare features within the project area were found. Two key changes are made to the document in response to this letter: 1. A new figure(Figure 5)displaying all significant ecological sites and biological diversity sites within a 1 mile radius of the project area is added. 2. Text for Question 11 and the Fish, Wildlife, and Ecologically Sensitive Resources section of the Focused Mitigation Initiatives was modified to include a discussion on potential impacts from development of the AUAR area and mitigation initiatives. Riley Purgatory Bluff Creek Watershed District(comment via email): Comments from the RPBCWD received via email on April 17,2017 focused on the Avienda development proposal.The first concern is regarding the preservation of the central wetland,and confusion as to whether or not both options preserve the wetlands. Figure 15 A has been modified so that it clarifies that Concept A does not preserve the central wetland while Concept B limits physical impacts to the wetland. AUAR Update Comments and Responses 26 April 2017 Page 3 There is also concern that the proposed development does not deliver on the development's theme to provide "A Healthy Way of Life"or the statement that"The physical environment emphasizes an attractive,comfortable walking experience for shoppers and visitors and is designed to serve trail users and mass transit as well as automobile traffic." These comments are more appropriately addressed through the development entitlement process specific to the Avienda project. Minnesota Pollution Control Agency: Letter is informative and requires no changes to the AUAR Metropolitan Council: Met Council is requesting that once a specific development program has been adopted that it will need to be reflected in the 2040 Comprehensive Plan Update.Also,they are requesting that data be provided on number of households to ensure the 2040 demographics forecast is correct. The Traffic Analysis Zone(TAZ)Forecasts in the City's 2040 comprehensive plan update will reflect the chosen development scenario. Residents at the"Preserve at Bluff Creek": The letter from residents from the Preserve at Bluff Creek Development focuses on two key topic areas specific to the proposed Avienda project: 1—traffic;2—development form/type and use which includes site design (landscaping,open space, buffering,transitioning). 1. Traffic: Perception of significant increase in traffic along Bluff Creek Boulevard once the Avienda development is completed that will impact the safety of surrounding residents.There is assumed to be a large increase in cut-through traffic as the connection to Powers Boulevard is made,aside from Avienda development traffic travelling along Bluff Creek Boulevard.The letter provided a couple solutions including the following:connect Bluff Creek Drive to Lyman Boulevard instead of Powers Boulevard, restricting sections of Bluff Creek Drive to residential access only or making the connection less direct. The proposed connection of Bluff Creek Boulevard from its current terminus to Powers Boulevard is included in the City's 2030 Comprehensive Plan. The Avienda development is proposing to limit cut- through traffic by constructing two roundabouts and narrowing travel lanes which will provide traffic calming along Bluff Creek Boulevard.The traffic analysis included in the AUAR update assumed a portion of the proposed development traffic from Avienda would utilize Bluff Creek Boulevard to travel west to destinations south on Audubon Road and west on Pioneer Trail. Based on the analysis,the projected build-out traffic volume along Bluff Creek Boulevard ranged from 3,000 ADT to 3,600 ADT. 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I , waoWpuel `Alaaaoulg • • 11 • a • eill Iksi Camey County Pu6Cu Workj )administration 11360.7r icway 212 Operations Suite 1 (Program Delivery Cologne NW'55322-8016 narks None(952)466.5200 tFa*(952)46(-5223 April 19, 2017 City of Chanhassen c/o Kate Aanenson Re: Development Review Comments: Chanhassen AUAR Update 2016-2017 — Powers Blvd— TH-212--Pioneer Trail—Bluff Creek Drive—Audubon Road—Lyman Blvd Thank you for the opportunity to review the subject development in the City of Chanhassen. Consistent with the County Comprehensive Plan and County Codes, the following are comments and recommended conditions of approval as requirements for an updated AUAR and any necessary permits to be issued for the project and specific development parcels/ proposals: 1. Related to traffic and infrastructure, and AUAR Figure 24, please provide for County review and approval an additional sub-report and figures of detailed intersection and related segment geometric design concepts with estimated costs, schedule by year, and table of proportionate cost sharing for the City, Developments, MnDOT, and County consistent with the County's cost participation policy. Costs to include intersection / lane upgrades; signal interconnect and signal / fiber communications; and lighting as needed. Intersections and related traffic movements with a LOS'E'or'F'and/or intersections highlighted for traffic signals may require additional lanes/ capacity or widening. In addition, plans for future, long term improvements may require upgrades to the Powers Blvd and TH 212 intersection(s) including adding a second lane on the TH 212/ Powers Blvd Westbound On-Ramp. This depends on the level of SB Left Turn volumes and the overall intersection green times and phasing. Powers Blvd at Pioneer Trail may also require dual SB/EB left turn lanes, more in the long term. As a note, such improvements should be balanced with scales and considerations for pedestrian crossings and operations and maintenance impacts and costs. 2. Related to traffic and infrastructure, and AUAR Figure 24, provide for County review and approval an additional sub-report and figures of the existing and County Comprehensive Plan recommended rights of way, including parcels adjacent to the AUAR related properties. 3. Related to stormwater and infrastructure, and AUAR Figure 17, provide for County review and approval some type of additional, declarative sub-report and figures of the specific plans and impacts to the stormwater and ditches on each County highway related to the AUAR. 4. Related to parks and trails, provide for County review and approval some type of additional, declarative sub-report and figures of the specific plans and impacts to the City and County regional and linking trails plan for the highways and areas related to the AUAR. 5. Related to utilities and infrastructure, provide for County review and approval some type of R:\Program Delivery\Transportation\Development Review\2017\2017-1 additional, declarative sub-report and figures of the specific plans and typical cross-section on each County highway related to the AUAR. 6. Provide for County review and approval at least prior to 30% plans and specs of roadways or access points intersecting with County highways. Specific areas of concern are that the Bluff Creek Drive road extension from Powers Blvd be designed for 2-lanes inbound through and around the proposed internal roundabout, such that adequate throughput is achieved at the critical Powers Blvd /TH 212 intersection. This 2-lane inbound for Bluff Creek Blvd is also consistent with the AUAR's notation for dual NB left turns on Powers Blvd at TH 212. 7. Prior to any work affecting or on County highways or in County right of way, the applicant shall coordinate plans with the County Engineer and obtain a Utility or Excavating/Filling/Grading Permit(s) from Carver County Public Works: (htto://www.co.carver.mn.us/how-do-i/apply-for/a-permit). Final details of locations, grades, and profiles affecting County roads as well as any utility connections will need to be reviewed and approved prior to any permits. 8. Any damages, modifications, or changes incurred on County highways from current or approved conditions will need to remedied or updated at development expense, including costs incurred by the County. These are comments at this time. If you have any questions or need further assistance, please do not hesitate to contact me at dmccormickPco.carver.mn.us or by phone at(952) 466-5208. Sincerely. Dan McCormick, P.E. PTOE Transportation Manager Carver County Public Works cc: Chad Braun (TE/ Permits) R:\Program Delivery\Transportation\Development Review\2017\2017-1 rnDEPARTMENT OF Metropolitan District , TRANSPORTATION Waters Building 1500 Counntyty Road B2 West Roseville, MN 55113 April 17, 2017 Kate Aanenson City of Chanhassen PO Box 147 Chanhassen,MN 55317 SUBJECT: Chanhassen 2016 AUAR MnDOT Review#AUAR 17-002 NW Quad US 212 and Powers Road (CR17), South of Lyman Blvd (CR18) Chanhassen, Carver County Dear Ms. Aanenson: Thank you for the opportunity to review the 2016 Chanhassen AUAR. Please note that MnDOT's review of this AUAR does not constitute approval of a regional traffic analysis and is not a specific approval for access or new roadway improvements. As plans are refined, we would like the opportunity to meet with our partners and to review the updated information. MnDOT's staff has reviewed the document and has the following comments: Design Continue to work with MNDOT on any of the proposed state highway changes suggested in this report. Any changes to the TH 212 interchange will require a Level 1 Layout review and approval. Diane Langenbach, MnDOT Area Engineer, can help guide you the process. For questions regarding these comments, contact Nancy Jacobson(nancy.l.iacobsonAstate.mn.us or 651-234-7647) in MnDOT's Metro Design Section. Review Submittal Options: MnDOT's goal is to complete the review of plans within 30 days. Submittals sent in electronically can usually be turned around faster. There are four submittal options. Please submit either: 1. One(1) electronic pdf. version of the plans. MnDOT can accept the plans via e-mail at metrodevreviews.dotAstate.mn.us provided that each separate e-mail is under 20 megabytes. 2. Three (3) sets of full size plans. Although submitting seven sets of full size plans will expedite the review process. Plans can be sent to: MnDOT—Metro District Planning Section Development Reviews Coordinator 1500 West County Road B-2 Roseville,MN 55113 An equal opportunity employer MnDOT Metropolitan District, Waters Edge Building, 1500 County Road B2 West, Roseville, MN 55113 3. One(1) compact disc. 4. Plans can also be submitted to MnDOT's External FTP Site. Please send files to: ftp://ftp2.dot.state.mn.us/pub/incoming/MetroWatersEdge/Planning Internet Explorer doesn't work using ftp so please use an FTP Client or your Windows Explorer(My Computer). Also,please send a note to metrodevreviews.dot@state.mn.us indicating that the plans have been submitted on the FTP site. If you have any questions concerning this review,please contact me at(651) 234-7784. Sincerely, Karen Scheffmg Principal Planner CC: Nancy Jacobson, Design Hailu Shekur, Water Resources Merlin Kent, Traffic Clare Lackey, Traffic Engineering Doug Nelson, Right-of-Way Buck Craig,Permits Diane Langenbach, Area Engineer Natalie Ries,Noise Bruce Wetherbee Russell Owen,Metropolitan Council MnDOT Metropolitan District, Waters Edge Building, 1500 County Road B2 West, Roseville, MN 55113 DEPARTMENT OF NATURAL RESOURCES Minnesota Department of Natural Resources Ecological and Water Resource 1200 Warner Road St.Paul,MN 55106 April 17,2017 Transmitted Electronically Kate Aanenson Community Development Director 7700 Market Boulevard Chanhassen, MN 55317 Re: Chanhassen AUAR 2016 Update Dear Kate Aanenson, The Minnesota Department of Natural Resources(DNR) has reviewed the Chanhassen 2005 Alternative Urban Areawide Review(AUAR)2016 Update.We offer the following comments. As noted in the section guidelines on page 22,prior consultation with the DNR Natural Heritage program for information about reports of rare plant and animal species in the vicinity is required for an AUAR. NHIS Reviews are valid for one year and are project and location specific.The results for one project will not necessarily be the same for another project,even if they are in the same general area.Therefore,using a Review for another project(page 23 notes an Environmental Impact Statement for the TH 212/312 expansion project contains additional information)may not be appropriate. In addition,the records presented in the 2017 AUAR are from communications that occurred in 2005.New records are added to the Natural Heritage Database on a daily basis and referring to data that was obtained in 2005 without prior consultation is not recommended.We strongly recommend that all projects be reviewed by the Minnesota Natural Heritage and Nongame Research Program prior to submitting an AUAR for public review. That said,an approximate one-mile radius of the project area was reviewed by DNR. Based on this review,there are no new known occurrences of rare features within the project area.There is an occurrence of a Minnesota Biological Site of High Biodiversity located just southwest of the project area that should be identified;this area is also designated as a Central Region Regionally Significant Ecological Area.These,and other natural resource GIS layers can downloaded from the Minnesota Geospatial Commons website at https://gisdata.mn.gov/group/51522a54-9af5-4f06-b1ad- 73cdb814cf65?o rga n izatio n=us-m n-state-d n r. As noted in the EAW Guidance Form,the AUAR should discuss whether the planned projects may potentially affect rare features.While there were no known occurrences identified within the project area itself,several were noted to have been identified within 1-2 miles that could potentially be indirectly affected as a result of project activities.The AUAR should include a discussion on how features identified may be impacted by the project. Thank you for the consideration of our comments. Sincerely, /s/Rebecca Horton Region Environmental Assessment Ecologist Minnesota Department of Natural Resources • Ecological and Water Resources 1200 Warner Road,St. Paul, MN 55106 Date: April 17, 2017 at 5:50:17 PM CDT To: Kate Anenson <kaanensonChci.chanhassen.mn.us> Cc: Claire Bleser <cbleserCTrpbcwd.org>, Karen Wold <KWoldCa�barr.com>, Scott Sobiech <SSobiech(&barr.com> Subject: RPBCWD Comments on Chanhassen AUAR Kate, Below are comments from the RPBWCD on the AUAR. There appears to be a discrepancy between the proposed development plan in the AUAR and the wetland permit application. There are two development options provided in the AUAR, both of which preserve the majority of Wetlands 1 and 2 in the center of the site. The preferred development option in the wetland permit application does not preserve any of these central wetlands.There should be some clarification, since it appears that the current plans do not preserve these central wetlands. The theme of the Avienda development is: "A Healthy Way of Life" and the project development statement: "The physical environment emphasizes an attractive, comfortable walking experience for shoppers and visitors and is designed to serve trail users and mass transit as well as automobile traffic." The development as proposed does not appear to meet either the them or this statement about the physical environment. The development plans appears to have been designed with roads and parking lots, eliminating nearly all wetlands and ignoring the natural layout of the land. It does not appear to incorporate walkability on trails or promote a natural healthy environment or lifestyle. The November 1, 2016 public hearing held before the Planning Commission raised concerns with loss of wetlands,tree loss, over grading of the site- ignoring the terrain, and walkability of the proposal. There was concern that the site is just another development with no unique charm or aesthetic qualities from any other development.There were concerns about whether businesses will be sustained in this development and comments that many businesses have failed in the area, leaving vacant buildings in addition a recent RPBCWD public survey indicated that protection and preservation of wetlands is a high priority for residents within the district. Based on public concerns, it appears the Avienda development should be designed to take advantage of the natural resources on the site, rather than the current plans, which appear to be working from a blank slate as if the area were a flat landscape. The development should be focused on preserving the central wetlands and design an enjoyable shopping experience to bring attention to this natural amenity, with paths for shoppers and neighbors to take a healthy break to appreciate the wetlands and natural features of the landscape. Thank you for the opportunity to provide input through the AUAR process. Scott Sobiech 952-832-2755 office 763-219-3479 cell www.barr.com �BI G Minnes ta Pollution Control Agency k. 520 Lafayette Road North I St.Paul,Minnesota 551554194 1651-296-6300 800657-3864 I Use your preferred relay service I Info.pca@state.mn.us I Equal Opportunity Employer April 17,2017 Ms. Kate Aanenson Community Development Director City of Chanhassen 7700 Market Boulevard Chanhassen, MN 55317 Re: Chanhassen 2005 Metropolitan Urban Service Area Alternative Urban Areawide Review Update Dear Ms.Aanenson: Thank you for the opportunity to review and comment on the Alternative Urban Areawide Review (AUAR) Update for the Chanhassen 2005 Metropolitan Urban Service Area project(Project)located in the city of Chanhassen,Carver County,Minnesota.The Project consists of on-going development of a 625-acre area. Minnesota Pollution Control Agency(MPCA)staff has reviewed the AUAR Update and have no comments at this time. We appreciate the opportunity to review thisProject. Please provide the 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 AUAR Update,please contact me via email at Karen.kromarCWstate.mn.us or via telephone at 651-757-2508. Sincerely, Karen Kromar Planner Principal Environmental Review Unit Resource Management and Assistance Division KK:bt cc: Dan Card, MPCA,St.Paul Teresa McDill,MPCA,St.Paul April 17,2017 Ms. Kate Aanenson Community Development Director 7700 Market Boulevard Chanhassen,MN 55317 RE: Chanhassen Metropolitan Urban Service Area(MUSA)Alternative Urban Areawide Review(AUAR) Metropolitan Council Review File No. 19028-2 Metropolitan Council District No.4 Dear Ms.Aanenson: Metropolitan Council staff completed its review of the Chanhassen Metropolitan Urban Service Area (MUSA)Alternative Urban Areawide Review(AUAR)to determine its accuracy and completeness in addressing regional concerns. This is an update to the MUSA AUAR adopted in 2003.The project area covers approximately 600 acres with the City that is generally bound by Lyman Boulevard on the north,Audubon Road on the west, Pioneer Trail on the south and Powers Boulevard on the east. Since the original AUAR,a significant amount of development has occurred but there are vacant parcels,most notably a 118 acre area designated as either office or regional commercial in the City's 2030 Comprehensive Plan.A Concept PUD for this area called Avienda is the impetus for the AUAR Update.The proposal includes approximately 118 acres of regional commercial,office,and medium/high density residential development. Staff concludes that the AUAR is complete and accurate with respect to regional concerns and does not raise major issues of consistency with Council policies. However,staff offers the following comments for your consideration: Transportation Analysis Zone(TAZ)Forecasts(Todd Graham, 651-602-1322) When the City chooses to proceed with a scenario,the City will need to reflect the chosen scenario in its 2040 comprehensive plan update. A draft set of TAZ forecasts for 2040 has been prepared by the Council and is available for local governments to review. Most of the Avienda site is located in TAZ#387.The office development on the east side of Hwy 212 is a small piece of TAZ#386.TAZ#387 is currently expected to gain+466 households during 2014-40.AUAR Scenario B fits approximately with this forecast. If Scenario A is pursued,602 housing units would be added in TAZ#387. Council staff recommend adjusting the TAZs forecast when the City chooses a scenario. Balancing adjustments can be made to TAZs elsewhere in Chanhassen.The City can update the TAZs table at the time of its plan update. 390 Robert Street North Saint Paul.MN 55101-1005 P.651 602 1000 I TTY.651.291.0904 ,, metrocouncil.org METROPOLITAN ' ,„„,; ,,;,.,,r,,,,s r ?,/;rCOUNCIL The Council will not take formal action on the AUAR. If you have any questions or need further information, please contact Angela R.Torres, Principal Reviewer,at 651-602-1566. ince,, • Lis' :eth Barajas Manager Local Planning Assistance CC: Steve O'Brien,MHFA Tod Sherman,Development Reviews Coordinator,MnDOT- Metro Division Deb Barber, Metropolitan Council District No.4 Angela R.Torres,Sector Representative/Principal Reviewer Raya Esmaeili, Reviews Coordinator N;1ConnnDevILPAICotnnnnitieslChanhassenlLeiterslChanhassen 19028-2 AUAR-OK with Cotnntents.doc Mayor Laufenburger and City Council Members, We are a group of concerned residents who live near the proposed Avienda development on the SW corner of Lyman and Powers Blvd. While we are very excited for the potential this development can bring to our community,there are issues that we believe must be addressed. Below we have listed our primary concerns and have also provided solutions that we feel will help guide the development into a sustainable and desirable community asset,and not just what the developer wants. We appreciate your time and effort in looking into our concerns and look forward to your response regarding their viability and any suggestions as to how the solutions may be implemented. Our first concern is the potential traffic on Bluff Creek Blvd and the safety risk for the current residents. • Bluff Creek Blvd interconnects the residential areas of Pioneer Pass,Liberty,and the Preserve at Bluff Creek,which services local families and young children. Please note that there are about 120 homes in the Preserve at Bluff Creek alone,and multiplying that with the MN census average of 2 children per household,that's 240 children in the immediate residential area along Bluff Creek Blvd from one neighborhood alone. If connected directly to the Avienda development without limiting through traffic,we are deeply concerned that Bluff Creek Blvd will become very difficult for pedestrians to cross,and potentially unsafe to cross by children in the neighborhood. • We are also concerned that the AUAR under-estimates the potential traffic increase since it does not seem to take into account that Bluff Creek Blvd is the most direct route between Avienda and to areas in the Southwest direction. Anyone traveling from the Southwest will use this route instead of going around the"main"roads to Avienda. Please see the Google Maps screenshot(at bottom)which automatically maps Bluff Creek Blvd and Dr as the fastest route if you want to get from the corner of Pioneer Trail and Audubon Rd to the planned Southwest entrance of Avienda. We already have an issue with individuals who don't reside in the neighborhoods using Bluff Creek Blvd as a pass through to avoid traffic lights. With the planned additional stop lights along Lyman Blvd,Pioneer Trail,and Powers Blvd,and the fact that Bluff Creek will now be connected to something of interest for non-residents,we feel that pass through traffic will become an even larger safety issue. • Solutions—We understand that Bluff Creek Blvd must be connected on the North side, but we are concerned with the significant increase in transient traffic in the residential area by having it be a direct path to the development area. Perhaps Bluff Creek Blvd could have its own connection with Lyman Blvd by connecting it due north from where it currently terminates. Avienda will then have its own access and exit which will not interfere with residents along Bluff Creek Blvd. Another option is to discourage non-resident,pass through or transient traffic as much as possible to and from Avienda. This could be done by restricting sections of Bluff Creek Blvd to residential access only and closing it to through traffic,and/or making the connection less direct for through traffic. The current traffic calming strategy of narrowing the lanes on Bluff Creek Blvd at Pioneer Pass Park and using roundabouts do next to nothing on preventing fast,pass through traffic. Please do not utilize this strategy as the only strategy for traffic calming for the Avienda development. Finally,since there are many families and children who cross Bluff Creek Blvd,please have the development focus on providing safe ways to cross this street,perhaps through the use of a sequence of speed bumps,and providing a large median for pedestrians to cross. We are also concerned with the type of development the developer is planning based upon current concepts for Avienda. We hold dear the natural landscape and beautiful scenery that exists around our neighborhood and in the development area. We welcome a development which shares those same values. However,looking at the proposed plans for Avienda,especially option A,we get the impression that the developer wants to pave over this land to cram in as many building and parking lots as possible, counter to the class and charm the residents,council members and Mr.Akradi have previously encouraged. • Development option A does not fit with the image of Chanhassen which places priority on green space and aesthetics. This option"pancakes"the entire scenic rolling hills and wetlands of the current landscape in the development area. It also removes a far larger section of the forest than was originally described in early project meetings. This area is found in the secondary zone of the Bluff Creek Overlay and is part of the Big Woods habitat of what the DNR defines as old- growth forest. Nearly all of option A's land use is allocated for large building and parking lots. The proposal itself allocates 0%of the land to parks or green space. • We are concerned that the developer wants to create another"me too" big box experience. We already have plenty of this type of development represented in the suburban area. Option A tries to cram in as many stores as possible and doesn't create anything unique when compared with other nearby cities and their offerings. • Option A favors large big box stores. Big box stores are struggling in today's online economy and relying on these types of stores in the future does not make sound financial sense. • Solution—Preserve the wetlands and forests,and keep as much green space as possible so they can be used as assets to create a unique experience for visitors. The retail economy has shifted towards providing shoppers an experience such as locally owned stores,aesthetic and walkable green open spaces(please recall previous city council meeting references to downtown Excelsior). This unique experience is what will keep visitors returning to this development for years to come,as well as promoting a sense of community for the residents in the nearby area. Please support the development of something more like option B vs.option A,with an increased focus on utilizing the topography while preserving and retaining local wetlands and old growth habitat. High density residential space • While we understand the need for additional housing we are concerned with how it's being planned for execution. Looking at Option A,a large multi-story,high density apartment complex would be right across the street from single family homes. This is a very jarring transition that is just not seen elsewhere in the suburbs and appears to conflict with local planning ordinances and city codes. Many residents along the border with the planned development are very concerned with seeing parking lots,and large commercial and residential building towering over their house whenever they look out the window. • We are concerned with the size/capacity of the proposed luxury high density residential building. The Wall Street Journal,MSN money as well as other news sources have written about how the demand for luxury rental has cooled and will continue to decline. Such a large building may no longer be supported by the market. https://www.wsi.com/articles/I uxurv-a partment-boom-looks-set-to-fizzle-in-2017-1483358401 https://www.msn.com/en-us/news/other/luxury-apartment-boom-looks-set-to-fizzle/a r- BBxOVNA • Solution- We would much rather see a transition from the existing low density housing to medium density housing along the entire shared border between the existing residential area and Avienda. Also,we would rather not have a high density residential space built,but if it is,it should be moderately sized and should have placed with a good buffer between existing single family homes. These are all aspects more reflected in Option B. Hotels • We are concerned with having hotels being proposed in the development and having people not from the community in such close proximity to a residential area as well as to the Chanhassen High School. • We do not understand the need for additional hotel space in Chanhassen. We do see that there Is a peak in interest for Paisley Park. However,we should not be building permanent establishments to accommodate for short term peak activity. We are doubtful that the existing hotels in Chanhassen are at max capacity on a consistent basis and do not believe that the market will support another hotel in the long run. • Solution—do not have hotels as part of the development. At minimum have the developer provide vetted financial analysis that another hotel is sustainable and if one must be built,it should be placed away from existing residential areas. Sincerely, Your fellow Chanhassen residents at the Preserve at Bluff Creek Ie«SC ?, ee is ft 't1ire:$ 414 -de ¢r .:: ;5'... 01112 . - - ... , , . . , . - Hcrekaoevatd .. ..., .4.-.,-.-3Thia”-- larnift ,.4. r: .r.,•!•:. . . , ' Az g , ii „..., . .,.. . . . . . - . ' Oil 3 min . _ nvio:or Cror110116.•:... *Bottom& k /.3 M 00 ', , Bluff Creek Golf Course Planes Trani!sx , • 0) 6711 forieur Rieue ..... Go gle Name Address Signature )0,4' )`t ge -escict e r - [Lai) <5"e-e-y-- E,4„c s- edir,coilk 6,cit /Neonve: e, Los-k_x_ gel ev ��c 17r 4j* „?.?, RolicA,9 r v 1 R1MoD v� I sbZ x;11 b,,„e_ P 1\44,,vv, 1041 Dalt,/ (1) , C e \qt, VAbegjekia CiktaQ, •► , i.44,4A01,Q4 -56\ e-Aj 6„c4u4d � I �! 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