October 25, 2000
National Park Service
Midwest Region
Attn: Mr. Marty Sterkel
1709 Jackson St
Omaha, NE 68102
Re: Review of and Comments on the Draft Environmental
 Assessment for the Fort Snelling Upper Bluff Athletic Fields Project

 Dear Mr. Sterkel:

Thank you for the opportunity to review and comment on the Draft

Environmental Assessment for the Fort Snelling Upper Bluff Athletic Fields

Project (Draft EA) submitted by the National Park Service. The development of the proposed Athletic Fields involves the grading of approximately 55 acres of land located within the jurisdiction of the Lower Minnesota River  Watershed District (LMWD) and water main installation and associated construction dewatering along the Highway 55 corridor within both  Minnehaha Creek Watershed District (MCWD) and LMWD jurisdiction.
 

 Neither the re-grading project, nor the affected outfalls to be used during or after the re-grading of the athletic fields fall within the jurisdiction of the MCWD however, a large portion of the water main installation and associated  dewatering does fall within the MCWD jurisdiction and within 1,500 feet of  Camp Coldwater Springs. Given the water main construction proximity to a hydrologically sensitive area (Figure 1), the MCWD has several recommendations regarding the Draft EA. They are as follows:

1. The proposed dewatering and bedrock excavation associated with installation of the water main will take place in three phases. The first and second phases of this project will take place within MCWD jurisdiction, and the third phase of water main installation takes place adjacent to the MCWD, within LMWD jurisdiction. Each phase has the potential to affect surface water features within the MCWD including area lakes and Camp Coldwater Springs. Rule N of the MCWD necessitates the procurement of a  construction permit from MCWD for these activities to proceed.
2. The work described in the EA requiring construction dewatering is scheduled to occur concurrent to other dewatering projects in the same area conducted by the Metropolitan Airports Commission (MAC). MCWD recommends that the potential combined impacts of the National Park Service and MAC dewatering be addressed in the EA.
3. The locations of planned bedrock excavation should be clarified in relation to the east-west bedrock valley near and south of Camp Coldwater Springs. The MCWD would be concerned about bedrock excavation occurring north of the bedrock valley. If it becomes necessary to excavate bedrock in that area, it must be demonstrated that it will not affect flow in Camp Coldwater Spring on a permanent basis.
4. The EA should clearly show the locations of planned dewatering associated with water main installation.
5. The EA should utilize existing ground water models monitoring data of the area to determine of the quantity of water that will be removed, and study the long and short term impacts of the planned dewatering. The results of the model should be used to determine weather or not a DNR groundwater appropriations permit will be necessary.
6. Allow the MCWD and the LMWD to review and comment on all construction plans as prior to bidding. MCWD is specifically interested in information regarding dewatering, infiltration, and bedrock excavation for the entire project
7. The EA should address ground water sampling in the vicinity of the dewatering necessary to determine if the dewatering will facilitate the migration or infiltration of contaminated ground water.
8. The EA should clarify the location of the infiltration pond to be used, provide information on the type of soils underlying the infiltration area and discuss the regulatory requirements of infiltrating the water removed from the construction area.

Please feel free to contact me at 612-471-0590 should you have any questions.

Sincerely,
 
  L Eric Evenson, District Administrator
MINNEHAHA CREEK WATERSHED DISTRICT
 

cc:Chuck Holtman, Smith Parker
Mike Panzer, Wenck
Kelton Barr, KBC