Preserve Camp Coldwater Coalition
A non-profit community-based advocacy group dedicated to preserve and protect the natural resources and restore the cultural integrity of the Camp Coldwater area, and to acquaint all people with the historic Birthplace of Minnesota.
www.preservecampcoldwater.org

Preserve Camp Coldwater Coalition
December 19, 2000

Minnesota Department of Transportation
Attn: Richard A. Stehr
Metropolitan Division
Waters Edge
1500 West County Road B2
Roseville, MN 55113

Dear Mr. Stehr:

Thank you for your response to the Preserve Camp Coldwater Coalition's letter of October 24, 2000 as requested by Governor Ventura. It is most heartening to see the Governor, Senator Paul Wellstone, Mayor Sharon Sayles Belton, and so many others, take a renewed interest in preserving historic Camp Coldwater and Coldwater Springs.

As noted in your letter, the Coalition requests that MnDOT stop work on its TH 55/62 interchange project due to concerns initially raised by consulting hydrologist Kelton Barr and then independently verified by Dr. Donald I. Siegel for the Minnehaha Creek Watershed District (MCWD). These concerns focus on documented impacts, both temporary and permanent, to the quantity and quality of the water flowing to and from historic Coldwater Spring caused by MnDOT's interchange alignment.

Mr. Barr is not alone in expressing these continued concerns. They are shared and voiced by the managers, staff and engineers of the MCWD, the Lower Minnesota River Watershed District (LMRWD), the Mn/DNR, various consultants, the Coalition, and many other individuals and groups who are aware of the sensitivity of this threatened historic natural resource. Minneapolis Mayor Sharon Sayles Belton and others have expressed their concern directly to Transportation Commissioner Elwyn Tinklenberg.

MnDOT developed an alternative ponding configuration in an attempt to address these concerns. Unfortunately, MnDOT's alternative will only lessen the impacts, not eliminate them.

Your second paragraph states "Many thorough studies have been made concerning the construction of the TH 55/62 interchange. The studies all conclude that there will be no permanent effect on Coldwater Springs." This is false. The MCWD emphasized this point in their November 29, 2000 letter to you in addressing the inaccuracies contained in your November 16, 2000 letter to the Coalition. The MCWD letter also states that "the potential for a problem, as reiterated by Kelton Barr, continues to exist" and that studies "clearly show that concerns about the reduction in flow to the spring are well founded.".

The attached Summary of Documents Finding Impacts to Coldwater Spring demonstrate that MnDOT's TH 55/62 interchange and ponding plans, including MnDOT's alternative design, will impact the quality and quantity of water flowing to and from historic Coldwater Springs. MnDOT has provided nothing in writing to substantiate their sole counter claims of no impact to Coldwater Springs.

Your letter continues: "The project has been approved by all necessary parties." The MCWD Managers have not approved MnDOT's TH 55/62 interchange or ponding configuration. Coldwater Springs lies within their jurisdiction. They believe, and have shown, that MnDOT's project will impact the very resource they are charged to protect. But their voiced concerns have been ignored in the approval process. This is unacceptable and in conflict with the May 24, 2000 Order of the Minnesota Board of Water and Soil Resources (BWSR) which established the joint MCWD and LMRWD jurisdiction of the Camp Coldwater watershed.

In its Order, the BWSR Board emphasized "the importance of ground water and the paramount importance of the protection of Camp Coldwater Spring." It further directed the LMWD to coordinate with the MCWD to avoid any possible adverse impacts of the MnDOT construction on the spring.

The LMRWD ignored this BWSR directive at its November 15, 2000 meeting in granting MnDOT its permit for Alternative #1. The LMRWD also ignored the MCWD's communication of concern and documentation of certain impact to Coldwater Springs by MnDOT's alternative configuration. At that meeting, the LMRWD relied solely on the verbal assurances of Daniel Dorgan, MnDOT spokesperson.

Mr. Dorgan stated to the LMRWD Board "It is still our position that the original pond design does not impact Coldwater Springs. And any of the three alternative designs, similarly, will not impact Coldwater Springs." The LMRWD Managers then failed to ask Mr. Dorgan to substantiate his claim with studies.

Rather than presenting evidence to back up his claims, Mr. Dorgan then committed the taxpayers of Minnesota to "repair" any damage to Coldwater Springs after the impacts are realized, now or in the future. MnDOT should not gamble taxpayer dollars to insure a plan only MnDOT believes will do no harm to Coldwater Springs. Rather, MnDOT owes it to the taxpayers of Minnesota to spend a fraction of that future fix money now to absolutely ensure the safety of Coldwater Springs.

MnDOT's planned elevation of the TH 55 reroute once threatened to impact Coldwater Springs. Then, as now, it was Kelton Barr and the MCWD Managers who brought this to light. The threat was resolved using the common-sense approach of raising the roadbed four feet. This small change eliminated the need to cut into the fragile underground recharge area of Coldwater Spring. It was a brilliant application of a simple solution to an imminent threat to Coldwater Spring. We commend MnDOT for recognizing and doing the right thing then by raising the roadbed elevation to save Coldwater Springs.

It is time for MnDOT to once again acknowledge the problem and do the right thing. The Coalition, and many others, now believe that MnDOT must reapply this simple and proven model to the TH 55/62 interchange. The threat to Coldwater Spring will be eliminated if MnDOT adequately raises the elevation of the interchange. By once again applying this common-sense, low-cost solution, MnDOT will not only save Coldwater Springs but will also save Minnesota taxpayers the increased cost of interchange redesign and reconstruction in the more-expensive future.

The Preserve Camp Coldwater Coalition calls on the BWSR Board to enforce its directives to the LMRWD and MCWD. BWSR must ascertain that its decision to create the conflicting jurisdictional alignment between the MCWD and LMRWD poses no threat to Coldwater Spring.

The Coalition calls on the MCWD Managers and staff to continue its advocacy work to protect the cultural and natural resources of historic Camp Coldwater and Coldwater Spring. We also recommend they insist on full and complete cooperation with the LMRWD to reach agreement on cross-jurisdictional disputes.

The Coalition calls on the LMRWD to work in concert with the MCWD. Its unilateral actions must stop. Any action or decision involving historic Camp Coldwater and Coldwater Springs must be made with the full support and approval of the MCWD. To do otherwise is to threaten Coldwater Springs. In light of this, the Coalition further requests the LMRWD to reopen the TH55/62 interchange permit process for MnDOT to substantiate its claims and to reach concurrence with the MCWD and DNR regarding impacts to Coldwater Spring.

The Coalition calls on the DNR to come forward and voice their known concerns over MnDOT's interchange configuration and its impacts to Coldwater Springs.

The Coalition again calls on MnDOT to stop construction now on the TH 55/62 interchange project until concurrence is reached with all parties that MnDOT's plans are environmentally and fiscally sound and will not harm historic Coldwater Springs.

MnDOT must make public any study or analysis that show the current TH 55/62 interchange plans will do no harm to Coldwater Springs. MnDOT's analysis, if it exists, must withstand the scrutiny of peer review as have Kelton Barr's. MnDOT must convince all agencies and individuals named jointly in our correspondence that MnDOT's TH 55/62 interchange project will do no harm to Coldwater Springs. The project must stop until all parties concur with MnDOT's claims of no adverse impact to Coldwater Springs.

The Coalition calls on Governor Ventura to coordinate the various factions of state government to work together to develop an interchange configuration that each and every party can attest will do no harm to historic Coldwater Springs.

Please feel free to contact me to discuss these issues and our requests for action. The Coalition stands ready to assist with any effort to ensure the continued flow of historic Coldwater Springs.


Sincerely,

Preserve Camp Coldwater Coalition

campcoldwater@yahoo.com


cc Governor Jesse Ventura
Commissioner Elwyn Tinklenberg, DOT
Commissioner Allen Garber, DNR
Ron Harnack, BWSR
Eric Evenson, MCWD
Kevin Bigalke, LMRWD
Robert Winter, MnDOT
Senator Paul Wellstone
Mayor Sharon Sayles Belton

Attachments: Summary of Documents Finding Impact to Coldwater Spring
September 29, 2000 MCWD Resolution of No Impact to Coldwater Spring
November 15, 2000 Letter Mayor Belton to Commissioner Tinklenberg
November 16, 2000 Letter Richard A. Stehr, MnDOT to the Coalition
November 29, 2000 Letter MCWD to Richard A. Stehr, MnDOT

Preserve Camp Coldwater Coalition
Page 4 of 4

Summary of Documents Finding Impacts to Coldwater Spring from MnDOT's TH 55/62 Interchange Preserve Camp Coldwater Coalition
1. 9/12/00 Kelton Barr Memorandum to MCWD "My calculations ? indicate that the construction dewatering and the
stormwater pond in the southwest clover leaf of the interchange, called the S.W. Loop Pond, could divert permanently one third or more of the flow to Camp Coldwater Spring."

2. 9/13/00 MCWD Letter to Daniel Dorgan, MnDOT Written by MCWD to alert Dan Dorgan and MnDOT to the issue "concerning
the potential groundwater impacts from the Highway 55/62 interchange and related construction." and why they believe the impact will be significant, resulting in a diversion "in excess of 18 million gallons of groundwater each year that otherwise would flow to Camp Coldwater springs.
"

3. 9/28/00 Dr. Donald I. Segiel Letter to MCWD
Peer review of Kelton Barr report that states "In conclusion, I agree with Kelton Barr (2000,a) that normal flow to Coldwater Camp Spring may be seriously inhibited by dewatering the unconsolidated sediments at the interchange area. I also believe that the SEH (2000) study was sufficiently flawed that a more rigorous analysis of the potential impact on spring volume is not possible from the data available at this time.

4. 9/28/00 MCWD Staff Memorandum to MCWD Managers

"Dr. Segiel concurs with Kelton Barr's September 12, 2000 report. He agrees that Mr. Barr's estimate of a flow reduction of 33 percent is plausible."

5. 9/28/00 Michael E Schoenberg Hydrogeologic Report.
Raised concerns that "the drainage pond will intercept groundwater flowing from the west that would have reached Camp Coldwater Spring. Second, groundwater to the east of the pond that would have flowed to Camp Coldwater Spring will flow into the drainage pond."

6. 9/29/00 MCWD Resolution
Requests that MnDOT, LMRWD, BWSR and DNR "ensure that the Spring suffers no adverse impact" and "of MnDOT that construction of the permanent pond and any related features, in any respect that may affect flow to the Spring, be discontinued until investigation is complete and actions to ensure no adverse impact to the Spring are decided on."

7. 11/6/00 MCWD (Michael Panzer, P,E., P.G.) Letter to Dennis Larson, MnDOT
"The original pond design, all of the alternative designs and the road subgrade design will permanently lower the shallow groundwater. The shallow groundwater gradients in the intersection area will also be altered. The MCWD has the concern that this could translate to a reduction in flow from Coldwater Spring and the associated seeps near the spring." "How much this will affect flow from the spring is unknown."

8. 11/10/00 MCWD Letter to Dennis Larson
"the Board concluded that it does not find Alternative 1 acceptable. In light of the commitment of the LMRWD and MnDOT, in the boundary change proceeding, to ensure the protection of flows to the spring, and BWSR's explicit reliance on that commitment to support its boundary change decision, it is the Board's view that the stormwater pond should be designed to have no impact on the spring."