II. 1. Blake Road Station EAWMEMO
To: Planning Commission Chair and Members
From: Andi Moffatt, Vice President of Environmental Services with WSB
Jason Lindahl, City Planner
Date: October 14, 2020
Subject: Blake Road Station Environmental Assessment Worksheet (EAW)
Proposed Action
Move to adopt Planning & Zoning Commission Resolution 2020-08, recommending the City
Council make a negative declaration of need regarding an Environmental Impact Statement for the
Blake Road Station Development.
Overview
Pursuant to Minnesota Rule 4410.4300, the City of Hopkins is the Responsible Government Unit
(RGU) for the Environmental Assessment Worksheet (EAW) for the proposed Blake Road Station
Development (Project). In this role, the City of Hopkins retained Andi Moffatt, Vice President of
Environmental Services with WSB to review the EAW prepared by the developer’s consultant,
Kimley Horn. Per the City Code Article II - Environmental Review Program, after an EAW is
prepared, the Planning & Zoning Commission shall review the EAW and recommend to the City
Council whether it should require the preparation of an Environmental Impact Statement (EIS).
The City Council shall require an EIS when it finds under Minnesota Rule 4410 that an action is
major and has potential for significant environmental effects.
Based on the review of the project, reasonably expected environmental impacts, and the findings of
fact and conclusions in this memo, it is our assessment that the project does not have the potential
for significant environmental effects and that where there may be environmental impacts, they can
be addressed through the permitting process. Through future land use review and permitting, the
City can consider the information obtained in the EAW process and address mitigation measures as
part of approvals or denials of a project. Therefore, staff recommends the Planning & Zoning
Commission adopt the attached resolution recommending the City Council make a negative
declaration of need regarding an Environmental Impact Statement for the Blake Road Station
Development.
Attachments
• Planning & Zoning Commission Resolution 2020-08
• EAW Appendix A – Comments Received
• EAW Appendix B – Response to Comments
• EAW Appendix C – Permits and Approvals Required
• EAW Appendix D – Supplemental Wastewater Information
Background
The purpose of an EAW is to determine whether an Environmental Impact Statement (EIS) is
needed. The EAW does not confer approval or denial of a project but rather is a tool to identify
issues or impacts that can and cannot be addressed through the permitting process. An EAW was
required to be prepared pursuant to Minnesota Rules 4410.4300, subpart 32 – Mixed residential and
industrial projects.
The EAW analyzes a standard list of questions based on Minnesota Rule and guidance from the
Minnesota Environmental Quality Board (EQB). The EQB is the State’s organization that oversees
the rules and implementation of Minnesota’s environmental review process. The standard list of
questions includes reviewing impacts to storm water quality and quantity, habitat, traffic, municipal
infrastructure, soils, land use, and a few other topics as noted in the EAW. The full Blake Road
Station EAW is available for review on the City’s website by clicking here.
EAW Review and Comment
The EAW was provided to the required review agencies and made available to the public on the
City’s website for the required 30-day comment period beginning on August 31, 2020. The comment
period ended September 30, 2020. No public hearing by the Planning & Zoning Commission or
City Council is required as part of this process. Comments through the EAW process can help
inform the permitting process and future steps for projects like this one. Eight comment letters
were received during the comment period and are attached in Appendix A. These comments letters
are from the state agencies and members of the public listed below.
• Minnesota Department of Natural Resources
• Minnesota Department of Transportation
• Minnesota Pollution Control Agency
• State historic Preservation Office
• Metropolitan Council
• Hennepin County
• Hopkins Community Housing Team
• Larry Hiscock, Hopkin Resident
The environmental review process requires RGU’s to respond to substantive comments related to
the required elements of the environmental review. Responses to comments have been prepared for
Planning & Zoning Commission and City Council review and are attached in Appendix B.
Findings of Fact and Conclusion
City staff has worked with our consultant, Andi Moffatt, Vice President of Environmental Services
with WSB, to review the EAW prepared by the developer’s consultant, Kimley Horn, and the
comments received from various state agencies and members of the public. Based on this review
and the criteria in Minnesota Rules, Part 4410.1700 and City Code Part III, Chapter 100, Article II –
Environmental Review, the City makes the findings of fact listed below and concludes the project
does not have the potential for significant environmental effects and EIS is not required for the
Blake Road Station Development.
1. Trilogy Real Estate Group is proposing the redevelopment of 6.4 acres of existing commercial
uses at the intersection of Excelsior Boulevard and Blake Road South in Hopkins, located
adjacent to the future METRO Green Line Blake Road Station. The proposed project is a multi-
modal transit-oriented development that will be constructed in three phases starting in the spring
of 2021. After the three phases are complete, the development will have up to 770 multi-family
dwelling units, up to 19,000 square feet of retail, and up to 950 parking stalls.
2. An Environmental Assessment Worksheet (EAW) was required for the project in accordance
with Minnesota Rules, part 4410.4300, subpart 32 (Mixed residential and industrial-commercial
projects).
3. The City of Hopkins is the Responsible Governmental Unit (RGU).
4. The EAW was prepared using the form approved by the Minnesota Environmental Quality
Board in accordance with Minnesota Rules, part 4410.1300.
5. The EAW is incorporated by reference in this Record of Decision.
6. The EAW was published in the EQB Monitor on August 31, 2020. The EAW was sent to all
persons on the EQB Distribution List and was posted on the City’s website.
7. The 30-day public review and comment period opened on August 31, 2020 and ended on
September 30, 2020. Eight comment letters were received and are included in Appendix A.
8. Based on the comments received, the City does not find any corrections are necessary to the
EAW.
9. The proposed project does not have the potential for significant environmental effects based on
the above findings and the evaluation of the following four criteria per Minnesota Rules, part
4410.1700, subpart 7:
a. Type, extent, and reversibility of environmental effects
b. Cumulative potential effects
c. Extent to which the environmental effects are subject to mitigation on ongoing public
regulatory authority
d. Extent to which environmental effects can be anticipated and controlled as a result of other
environmental studies undertaken by public agencies or the project proposer, including other
Environmental Impact Statements (EISs)
CITY OF HOPKINS, MINNESOTA
HENNEPIN COUNTY, MINNESOTA
PLANNING & ZONING COMMISSION RESOLUTION 2020-08
A RESOLUTION RECOMMENDING THE CITY COUNCIL MAKE A NEGATIVE
DECLARATION OF NEED REGARDING AN ENVIRONMENTAL IMPACT
STATEMENT FOR THE BLAKE ROAD STATION DEVELOPMENT
WHEREAS, the City of Hopkins prepared an Environmental Assessment Worksheet
(EAW) for the Blake Road Station Development pursuant to Minnesota Rules 4410; and
WHEREAS, the EAW was distributed to the agencies and public for the required 30-day
comment period August 31, 2020; and
WHEREAS, the 30-day comment period ended on September 30, 2020; and
WHEREAS, the preparation of the Blake Road Station EAW and comments received on
the EAW have generated information adequate to determine whether the proposed project has the
potential for environmental impacts; and
WHEREAS, the EAW has identified areas where the potential for environmental effects
exist, but appropriate measures have or will be incorporated into the project plan and/or permits to
reasonably mitigate these impacts; and
WHEREAS, the development is expected to comply with all the City of Hopkins and
review agency standards; and
WHEREAS, based on the criteria established in Minnesota Rules 4410.1700 and the
Findings of Fact and Conclusions, the project does not have the potential for significant
environmental effects; and
WHAREAS, as required by City Code Part III, Chapter 100, Article II – Environmental
Review, the Planning & Zoning Commission of the City of Hopkins reviewed all the information in
the staff memo dated October 14, 2020 and agreed with the findings detailed in the staff memo; and
NOW, THEREFORE, BE IT RESOLVED, that the Planning & Zoning Commission of
the City of Hopkins hereby recommends the City Council of the City of Hopkins make a negative
declaration of need regarding an environmental impact statement for the Blake Road Station
Development.
Adopted this 14th day of October, 2020.
____________________________________
Gerard Balan, Chair
Blake Road Station Development
Findings of Fact and Conclusions
Appendix A
Comments Received
Blake Road Station Development
Findings of Fact and Conclusions
Appendix B
Response to Comments
Blake Road Station Development B-1
Findings of Fact and Conclusions
Commenter Comment Response
Minnesota Department
of Natural Resources
Page 5, Table 4. This table in the EAW should acknowledge
that there may be a need for a DNR Water Appropriation
Permit should there be a need for construction dewatering
of surface water or ground water in volumes that exceed
10,000 gallons per day, or one million gallons per year.
This include construction dewatering for placing new
utilities to the site, constructing footings for the new
buildings, or grading the site.
Under Item 11.b.iii. the EAW states that if
dewatering is required for construction, a permit
will be obtained from the DNR. The dewatering
permit has been added to the permits and
approvals table in Appendix C.
Page 8, Groundwater. The site is located within the
Drinking water Supply Management Area of the City of
Edina. Pollutants that are spilled in this area will be in the
drinking water of the City of Edina within ten years.
Potential groundwater pollutants should be handled
carefully.
A spill prevention plan will be developed, and
proper spill prevention controls will be in place
for any vehicle refueling or maintenance that
occurs on site during construction.
Page 9, Stormwater. The large amount of impervious
surfaces within the project area will require the use of
winter road salt. Chloride released into local lakes and
streams does not break down, and instead accumulates in
the environment, potentially reaching levels that are toxic
to aquatic wildlife and plants. The runoff from this
development flows to Minnehaha Creek, which is already
impaired from excess chloride levels. Consider promoting
local business and city applicator participation in the Smart
Salting Training offered through the Minnesota Pollution
Control Agency. More information and resources can be
found at this website. Many winter maintenance staff who
have attended the Smart Salting training — both from
cities and counties and from private companies — have
used their knowledge to reduce salt use and save money
for their organizations.
The project proposer will look for ways to
minimize chloride use and improve treatment of
stormwater runoff to minimize potential impacts
to downstream waters. The project will comply
with all city, watershed district, and state rules for
stormwater management and will prepare a
Stormwater Management Plan that will be
reviewed by the city and watershed district.
Blake Road Station Development B-2
Findings of Fact and Conclusions
Commenter Comment Response
Page 17, Transportation. If the parking spaces beneath the
buildings need to be dewatered on a permanent basis, and
the volumes exceed 10,000 gallons per day, or one million
gallons per year, then a DNR Water Appropriation Permit
is required for the dewatering.
If permanent dewatering is required and volumes
exceed 10,000 gallons per day or one million
gallons per year, a DNR Water Appropriation
Permit will be obtained. The dewatering permit
has been added to the permits and approvals
table in Appendix C.
The DNR concurs with the EAW’s assessment that there are
no known occurrences of rare features within a one-mile
radius of the proposed project.
Comment noted.
Minnesota Department
of Transportation
Consider using raised crossings to slow vehicles and
provide a more intact pedestrian realm. Consider utilizing
driveways entries similar to MnDOT Standard Plan 5-
297.254 that indicate clear ROW priority for sidewalk users
and maintain an adequate pedestrian access route.
The project proposer will evaluate using a raised
crossing to slow vehicles entering the project site.
These details will be finalized as design
progresses.
MnDOT recommends that “Inverted-U” or “Post and ring”
type bike racks be utilized for the short term bicycle
parking as highlighted in the precedent imagery.
Renderings appear to show spiral type bike racks which
have some functional downsides such as users needing to
lift their bikes over the bottom of the rack.
The project proposer will evaluate the potential to
utilize “inverted-U” or “post and ring style” bike
racks for the development. These details will be
finalized as design progresses.
Minnesota Pollution
Control Agency
Wastewater
Item 11.b. states an approximate flow of 212,900 gallons
per day. A table itemizing the different land use types,
number of units, and design flow per unit should be
added.
Design wastewater flow calculations should be
included for both average daily flow and peak flow.
Based on the Metropolitan Council’s Sewer
Available Charge determination standards for the
proposed improvements with the proposed uses,
the maximum wastewater flows are projected to
be approximately 212,900 gallons per day (gpd)
at full buildout over the next 10 years. The
average daily flow is assumed to be
approximately 53,225 gpd. The existing site
consists of three retail buildings totaling
Blake Road Station Development B-3
Findings of Fact and Conclusions
Commenter Comment Response
An estimate of the actual current flows would also
be useful to better describe if there is an increase
in flow expected.
The direction of flow, and general sewer route to the
wastewater treatment plant (WWTP) should be mapped.
The design capacity, current flow, and capacity after the
redevelopment should be shown for sewers downstream
to the WWTP.
Item 11.b. states that flow increases to the lift station
serving the site would likely require improvements to the
lift station. If flow increases are expected from the
proposed Project, a brief description of the necessary lift
station improvements should be included.
The capacity of the WWTP and capability to accept this
increased flow should be discussed.
approximately 95,300 square feet, which equates
to 8,561 gpd maximum daily load and 2,140
average daily load.
The sanitary sewer service will be provided by the
City of Hopkins. The existing system currently has
the capacity to handle the increase in wastewater
generated by this type of development based on
coordination with the City’s Public Works
Department. A sewer line to service the three
buildings will be stubbed off of the existing
sanitary main in Excelsior Boulevard. An existing
public sanitary sewer lift station exists in an
easement on the south side of the project site,
adjacent to Excelsior Boulevard; however, this lift
station will not be impacted by the proposed
development. The new sewer services will connect
out into a gravity main in Excelsior Boulevard
such that they will not connect to the lift station.
Manholes will be provided every 200 feet to
provide access to the main line on the project site
for serviceability and monitoring.
The project site will be served by the publicly
owned Metropolitan Council Metro Wastewater
Treatment Plant in Saint Paul. The plant currently
treats approximately 172 million gpd, with a total
capacity of up to 251 million gpd according to
the Metropolitan Council Environmental Services
Publications and Resources. Based on the Sewer
Availability Charge Guidelines, the estimated
wastewater from the proposed mixed-use
Blake Road Station Development B-4
Findings of Fact and Conclusions
Commenter Comment Response
development is anticipated to consist primarily of
normal domestic sewage. The 10-year plan is
expected to generate approximately 212,900 gpd
(0.213 million gpd). The Metro Wastewater
Treatment Plant can treat the volume and
composition of wastewater generated by the
proposed project without pretreatment or other
plant facility improvements.
The average daily and peak flow information is
included in Appendix D.
Stormwater
The Project is a re-development with plans to install
raingardens and an underground filtration system for
stormwater treatment. The site is currently impervious with
green space to be added. The MPCA encourages the
Project proposer to also incorporate trees, perhaps in the
form of tree trenches, into the site plan to help mitigate
stormwater runoff.
Because the site will discharge to an impaired water within
one mile, the EAW should include the additional best
management practices, such as stabilizing soils
immediately and within seven days, which will be required
by the National Pollutant Discharge Elimination
System/State Disposal System General Construction
Stormwater permit.
The proposed project will include boulevard trees
and other plantings within the project site. The
project proposer and the City will evaluate if tree
trenches can be incorporated into the site design.
The EAW states that the project will require a
National Pollutant Discharge Elimination System
(NPDES) permit. A Stormwater Pollution
Prevention Plan (SWPPP) will be developed in
accordance with the NPDES permit and will
include best management practices such as
stabilizing soils immediately and within seven
days.
Blake Road Station Development B-5
Findings of Fact and Conclusions
Commenter Comment Response
Contamination/Hazardous Materials/Wastes
The Phase II Environmental Site Assessment determined
the presence of contamination at the Project site. The
MPCA recommends the Project be enrolled in the MPCA
Brownfields Program to obtain the necessary technical
assistance in managing the contamination. Information
regarding the Brownfields Program can be found at:
https://www.pca.state.mn.us/waste/brownfields.
Please note that for petroleum spills that are five or more
gallons, the Project proposer or their contractors are
required to contact the State Duty Officer at 651-649-5451
or 800-422-0798. Information on reporting spills and leaks
is available on the MCPA website at:
http://www.pca.state.mn.us/index.php/view-
document.html?gid=2807.
The project proposer will work with MPCA
regarding contamination and cleanup of the
project site as the site is redeveloped.
If a petroleum spill of five or more gallons occurs
on site during construction, the State Duty Officer
will be contacted as required.
Noise
The MPCA appreciates the discussion of noise in this EAW
but would like to add some comments.
Though the City of Hopkins has some noise-
related ordinance language, particularly exempting
construction noise, the Project is still subject to the
state noise standards defined at Minn. R. ch. 7030.
Although construction noise is temporary in
nature, we typically recommend that construction
activities take place during daytime hours (7:00 am
to 10:00 pm), and that construction equipment be
muffled, as appropriate.
The City and project proposer acknowledge that
the project is subject to state noise standards.
Equipment will be muffled as appropriate and the
contractor will consider other measures to further
minimize noise during construction.
Blake Road Station Development B-6
Findings of Fact and Conclusions
Commenter Comment Response
At this time, it seems unlikely that there will be any
long-term impacts (additions) to area noise from
the Project post-construction. Increased local
traffic, light rail trips, and other retail uses,
however, may impact the noise levels both current
and future residents experience in the area. So
long as the multi-family dwellings are constructed
to attenuate noise appropriately (as suggested in
the EAW), there should be no reason to believe
tenants will experience levels of noise above the
state standards while in their homes.
State Historic
Preservation Office
Based on our review of the project information, we
conclude that there are no properties listed in the National
or State Registers of Historic Places and no known or
suspected archaeological properties in the area that will be
affected by this project.
Please note that this comment letter does not address the
requirements of Section 106 of the National Historic
Preservation Act of 1966 and 36 CFR § 800. If this project is
considered for federal financial assistance, or requires a
federal permit or license, then review and consultation
with our office will need to be initiated by the lead federal
agency. Be advised that comments and recommendations
provided by our office for this state-level review may differ
from findings and determinations made by the federal
agency as part of review and consultation under Section
106.
Comment noted.
Blake Road Station Development B-7
Findings of Fact and Conclusions
Commenter Comment Response
Metropolitan Council The staff review finds that the EAW is complete and
accurate with respect to regional concerns and does not
raise major issues of consistency with Council policies. An
EIS is not necessary for regional purposes.
We offer the following comments for your consideration.
Comment noted.
Item 9b – Planned Land Use
Although no change in guiding land use is necessary, the
project would result in greater development than the City’s
2040 comprehensive plan anticipated. The project is
located in the southeast corner of Transportation Analysis
Zone (TAZ) 1407, where the City’s comprehensive plan
allocated a gain of 673 jobs and a loss of 50 households by
2040. In contrast, the project as proposed would result in
as many as 770 housing units, which are anticipated to be
built in phases through 2031. This compares to a citywide
forecasted growth of only 800 households from 2020-
2040.
Should development proceed and outpace forecasted
growth, the Council expects that the City initiate a
commensurate forecast increase through a comprehensive
plan amendment. The City could include the forecast
adjustment as part of an unrelated comprehensive plan
amendment or submit the amendment separately. The
Council recommends that the City request to increase its
official forecasts by 800 households and 1,700 population,
with assignment of this growth to TAZ 1407. Please be
advised that a future forecast increase for the 2021-2030
decade will result in an increase in the City’s allocation of
affordable housing need.
The City will continue to monitor growth in the
vicinity and will coordinate with the Metropolitan
Council accordingly.
Blake Road Station Development B-8
Findings of Fact and Conclusions
Commenter Comment Response
Item 11b – Stormwater
Council staff recommends that the developers and the City
consider the utilization of green roofs and biosolar (green
roof + solar) systems as stormwater BMP features
integrated with proposed ground-level stormwater BMPs.
MPCA’s online “Stormwater Manual,” which offers
guidance for designing and calculating stormwater
retention and detention values:
https://stormwater.pca.state.mn.us/index.php/Green_roofs
The Council’s “Surface with Purpose” tool offers technical
assistance for projecting green roof stormwater retention
capabilities:
https://metrocouncil.org/Communities/Planning/Local-
Planning-Assistance/Solar/Surface-with- Purpose-
Interactive.aspx
The project proposer states they will evaluate the
potential for incorporating green design elements
into the proposed project design and the
buildings will be designed to be rooftop solar
ready. The City strongly recommends the project
proposer incorporate any such items into their
land use application. Such items would help
support the project proposer’s request for a
Planned Unit Development (PUD) approval.
Item 12 – Contamination/Hazardous Materials/Waste
The site lies within the Drinking Water Supply
Management (DWSMA) for the city of Edina and is near
the Emergency Response Area (ERA) for Edina wells
numbered 12 and 13. ERAs are equivalent to the one-year
time of travel to these wells. While any contamination at
the development site is unlikely to immediately impact the
City of Edina’s drinking water supply, it would be useful for
the City of Hopkins to coordinate wellhead protection
activities with the City of Edina. The TCE detected on site is
a concern. Proper tracking and removal of detected
contamination to limit any mobilization that may impact
drinking water sources is essential. Hopkins may also want
to consider a chloride management plan for the site to
The City of Hopkins will continue to monitor and
coordinate wellhead protection activities with the
City of Edina.
Water demand calculations are included in
Appendix D. City staff has concluded that the
existing domestic water system has capacity for
the proposed project demand.
Blake Road Station Development B-9
Findings of Fact and Conclusions
Commenter Comment Response
limit any potential impacts of road salt on groundwater
and surface water resources.
Potential impacts of the development on water demand
for the City of Hopkins are not discussed in the EAW. The
site proposes 752 additional multi-family housing units. If
the current estimated persons per household for the City
are applied to this site, an estimated 1,579 residents may
be added at capacity. The Hopkins Local Water Supply
Plan, which is part of the City’s 2040 comprehensive plan,
estimates an additional 1,800 people to be added to the
City’s serviced population by 2040, the majority of which
would be part of the Blake Road Station Development.
Although increased demand of this magnitude is unlikely
to dramatically impact the City’s drinking water resources
or infrastructure, it would be useful to consult with the
Hopkins utility staff to ensure that demand can be met and
that water use efficiency is considered a priority for the
site. Council staff recommend that any irrigated land that
is included on the site be controlled by smart irrigation
technology that considers local rainfall and temperature
data to limit the need for outdoor water during the
summer months, when groundwater resources may be the
most stressed.
Item 16a – Stationary Source Emissions
The EAW states: “No stationary source emissions are
anticipated; therefore, no mitigation is required.” However,
the project will utilize boilers, exhaust stacks, natural gas,
and electricity. All of these are sources of greenhouse gas
emissions and air pollutants. In the response to Item 20,
the EAW states: “The project will enroll in the Xcel Energy
Comment noted. As stated, the project will enroll
in the Xcel Energy Design Assist (EDA) program to
optimize energy design strategies. Energy
efficiency with performance functionality will be
aggressively deployed to achieve sustainable
conservation and ongoing reduction of the
project’s carbon footprint. Rain gardens, solar
Blake Road Station Development B-10
Findings of Fact and Conclusions
Commenter Comment Response
Design Assist (EDA) program to optimize energy design
strategies. Energy efficiency with performance functionality
will be aggressively deployed to achieve sustainable
conservation and ongoing reduction of the project’s carbon
footprint.” Council staff encourage revising the response to
include the mitigation efforts planned.
ready rooftops, and energy efficient buildings will
be designed and constructed for the proposed
development.
Item 16b – Vehicle Emissions
The EAW states: “Motor vehicles emit a variety of air
pollutants including carbon monoxide (CO), hydrocarbons,
nitrogen oxides, and particulates.”
As also recommended above under Item 11b, Council staff
recommends that the developers and the City consider the
utilization of green roofs and biosolar (green roof + solar)
systems as stormwater BMP features integrated with
proposed ground-level stormwater BMPs. Increasing
rooftop vegetation leads to decreased ambient
temperature, decreased energy use, and directly removes
NO2, all of which reduce the formation of ozone and
mitigates for the air pollutants and emissions this
development will increase or introduce to this site. Please
see links to the MPCA and Council resources identified
above under Item 11b.
Council staff recommends the adoption and integration of
either electric vehicle charging infrastructure, or electric
vehicle-ready charging infrastructure, to complement the
TOD nature of this development, and to mitigate for those
vehicle emissions. Guidance can be found in the Great
Plains Institute’s “Becoming Electric Vehicle Ready”
guideline document. Such actions would be in direct
The buildings will be designed to accommodate
rooftop solar. Electric vehicle charging stations
will also be installed as part of the development.
The City strongly recommends the project
proposer incorporate any such items into their
land use application. Such items would help
support the project proposer’s request for a
Planned Unit Development (PUD) approval.
Blake Road Station Development B-11
Findings of Fact and Conclusions
Commenter Comment Response
support of the following policies in the City’s 2040
comprehensive plan:
GOAL 4: Protect and improve indoor and outdoor
air quality
o Support a reduction in vehicle emissions by
improving travel efficiency and promoting
non-auto modes of transportation,
including walking, biking, and public
transportation alternatives.
o Support expanded use of vehicles that do
not rely on fossil fuels.
o Foster air quality improvements to preserve
the natural environment and sustain
community health and enjoyment.
o Expand use of energy-efficient and
alternative fuel vehicles, including through
the city fleet.
Item 18a – Transportation
Metro Transit appreciates the City’s and the developer’s
continued engagement to ensure that the project is
integrated with, and meets the needs of, future transit
service including the METRO Green Line.
Comment noted.
Item 20 – Other Potential Environmental Effects
The proposed development increases the existing urban
heat island (UHI). The development would slightly
decrease the site’s impervious surface footprint (8%) but
more than triple the thermal mass of concrete from three
1.5-story buildings to three 7-story buildings (proposed).
Doing so increases the demand on the electrical grid to
meet cooling load requirements, increases the cost of
The project proposer will work with the City of
Hopkins on additional resiliency efforts to be
incorporated into the project if they are deemed
financially feasible. The buildings will be designed
to be rooftop solar ready. Electric vehicle
charging stations will also be installed as part of
the development. The City strongly recommends
the project proposer incorporate any such items
Blake Road Station Development B-12
Findings of Fact and Conclusions
Commenter Comment Response
operating due to higher cooling load demands, and
increases the volume of NO2 and ozone formation.
Council staff recommends that the developers and City
consider mitigation of UHI effects by installing green roofs,
vertical green walls (example: Mozaic Art Park Ramp’s
eastern exterior wall), cool roofs, planting and maintaining
trees, incorporating trees into site design, and constructing
cool, reflective, and permeable pavements (See
Metropolitan Council, “Keeping Our Cool: Extreme Heat in
the Twin Cities Region”).
Council staff recommends that the developers and City
consider integrating solar panels, BioSolar systems, solar-
ready construction, or green roof-ready construction into
the design of the proposed buildings. Solar panels may be
sited on the roof and exter ior walls of the buildings. The
City may look to the rooftops of The Liberty Apartments
complex in Golden Valley as a current example. If the site
is not suitable for on-site solar development, the
developers may pursue a subscription to a Community
Solar Garden through the cost-free technical assistance
provided by programs like GreenStep Cities, SolSmart, and
CERTs. Such actions would be in direct support of the
following policies in the City’s 2040 comprehensive plan:
GOAL 2: Reduce the overall disposal of solid waste
and increase reuse and recycling to conserve
environmental resources
o Support the development and use of
renewable energy sources in Hopkins,
including solar, wind, geothermal, biomass,
and other alternatives.
into their land use application. Such items would
help support the project proposer’s request for a
Planned Unit Development (PUD) approval.
Blake Road Station Development B-13
Findings of Fact and Conclusions
Commenter Comment Response
o Promote balance between the benefits of
urban forests and the benefits of enabling
solar development.
o If opportunity arises, participate in the
creation of local community solar gardens
for residents and businesses who have
limited on-site solar resources or do not
own land or buildings, on sites such as the
landfill.
o Encourage development projects to
evaluate on-site solar opportunities and
incorporate solar system installation into
designs.
Hennepin County Hennepin County transportation has reviewed the above
document, along with the traffic study again.
We had previously reviewed and discussed our comments
to the traffic study with the city and your consultant, and
have no additional comments to make at this time.
I understand that discussions regarding the right-in right-
out access on both Blake Road and Excelsior Blvd continue,
and that the county and Hopkins are continuing to plan
for turning back Blake Road to the city.
Comment noted. Coordination with Hennepin
County regarding access and roadway jurisdiction
will continue.
Hopkins Community
Housing Team
Thank you for this opportunity to provide comment on the
Environmental Assessment Worksheet (EAW) for the
proposed Blake Road Station development. We are deeply
concerned that the draft proposal and the EAW fail to take
into consideration “vulnerable populations” adjacent to the
development as well as the displacement of
neighborhood-serving and minority-owned businesses,
will accelerate increasing rents displacing long-time
Minnesota administrative rules govern the
required elements of an EAW and the Minnesota
Environmental Quality Board (EQB) publishes a
standard form for the preparation of an EAW. The
EAW was prepared in accordance with state rules
and EQB guidelines. Environmental justice
Blake Road Station Development B-14
Findings of Fact and Conclusions
Commenter Comment Response
neighbors and community-serving businesses, and that
the cumulative impact of this project with the 325 Blake
Road development and other potential developments in
the Blake Road station area will be harmful to a
surrounding neighborhood that fits the definition of an
Environmental Justice Community. Additionally, we are
concerned that more could be done to engage the
surrounding neighbors to understand the opportunity and
the consequences, and to inform the community of
potential mitigation measures.
As documented by the Southwest Corridor-wide Housing
Inventory completed by Hennepin County’s Southwest LRT
Community Works, housing in the Blake Road station area
of Hopkins is primarily naturally occurring affordable
housing. This report counts 16 multi-family rental
developments (of 12+ units) within the Blake Road station
area in Hopkins. For the 13 (out of 16) market-rate
properties for which rents were known at the time of the
study, all are affordable at 60% AMI or less, with most
affordable at 50% AMI.
According to the Housing Inventory, “the Blake Road
station area had the highest population with nearly 5,400
persons” within a half-mile radius. The report also notes
that the Blake Road station area has one of the highest
populations of people of color (52%), the highest percent
(26%) of people 19 years old and younger, and was one of
only four that averaged over two people per household.
While housing in the Blake Road neighborhood has
provided a more affordable place to live for many Hopkins
residents, with much of this housing being market-rate,
analysis is not required for projects without
federal funding or approvals.
State administrative rules also include standards
and criteria for the decision on the need for an
Environmental Impact Statement (EIS), based on
the potential for significant environmental
effects. State rules defines environment as land,
air, water, minerals, flora, fauna, ambient noise,
energy resources, and artifacts or natural features
of historic, geologic, or aesthetic significance.
Through the EAW, it was determined that the
project does not pose a potential for significant
environmental effects, therefore an EIS is not
warranted.
As stated in the EAW, the site located at 325 Blake
Road was purchased by the Minnehaha Creek
Watershed District (MCWD) in 2011 with the
intent to use 4 to 6 acres of the site for
stormwater management and use the remaining
land for redevelopment. MCWD and the City of
Hopkins have been working together to prepare
the site for redevelopment and anticipate going
out for developer selection in the near future,
with the intent for redevelopment to begin in
2021. The City has not yet approved a
redevelopment plan for the 325 Blake Road site;
however, as indicated in the 2040 comprehensive
plan, the site is zoned for an Activity Center. After
a development proposal is submitted for this site,
Blake Road Station Development B-15
Findings of Fact and Conclusions
Commenter Comment Response
there is no guarantee that the rental prices will remain at
more affordable levels into the future. As new market-rate
buildings like the proposed Blake Road Station
development arrive in the neighborhood, nearby
properties, both housing and commercial, will face
increasing pressure.
Therefore, our concerns regarding the EAW include the
following:
1. The proposal and EAW do not reflect the City of
Hopkins’ expressed commitment to racial, cultural, and
economic diversity nor the priority of racial equity
referenced in the 2040 Comprehensive Plan,
2. The proposal and the EAW do not reflect community-
wide input supporting affordable housing, fears of
gentrification, nor the priorities of adjacent neighborhood
residents stating that affordable housing is their top
priority,
3. The proposal and the EAW do not address the
displacement of neighborhood and community-serving
businesses, the displacement of minority-owned
businesses, nor the priorities expressed by adjacent
neighborhood residents for access to such businesses,
4. The EAW is incomplete because it does not perform a
Cumulative Potential Effect analysis of the proposed
development on the vulnerable populations immediately
adjacent to the development. Nor does it consider the CPE
of both the Blake Road Station development and 325
Blake Road on the surrounding vulnerable populations.
the project will be addressed via the regulatory
permitting and approval processes and will be
individually mitigated to ensure minimal
cumulative impacts occur.
Public comment on the proposed project has
been solicited in multiple ways. The project
proposer created a project website
(https://blakeroadstationdevelopment.com) in
June 2020 with project information and a method
for contacting the developer to ask questions and
provide comments. The project proposer has met
with community groups upon request.. The City
has also provided information about the
proposed project on their website, including the
concept plan and EAW. The City is following the
required process for public review for the
environmental document, and additional
opportunities for commenting on the proposed
project are available as part of the land use
application review.
Blake Road Station Development B-16
Findings of Fact and Conclusions
Commenter Comment Response
5. And we are concerned that the adjacent community that
will be most burdened by the project are unaware of the
proposed project, the impacts, potential mitigation
measures nor the opportunity to comment on the EAW.
Given these concerns, we request the following:
1. That a supplemental Cumulative Potential Effects
analysis be conducted to understand the impacts on the
surrounding community that stand to be
disproportionately burdened and meet the definition of an
Environmental Justice community. The CPE must also
include mitigation measures.
2. A full Environmental Impact Assessment be conducted
with a focus on the social and economic impacts this
proposed development along with the other significant
Transit Oriented Developments in the station area will have
on existing affordable housing and on low and moderate
income households. Low and moderate income
households were to be key beneficiaries of the METRO
Green Line Extension in the form of affordable, reliable
transportation to regional employment centers. The
benefit of the line is lost if they are displaced to
communities lacking public transportation.
3. Extend the comment period to allow for additional
public comment and for the City of Hopkins to distribute
flyers to the affected community soliciting further input
and/or host a socially distant event outdoors to educate
the community and gather further comment.
4. That the City of Hopkins and developer conduct a racial
impact analysis to minimize burdens and maximize
Blake Road Station Development B-17
Findings of Fact and Conclusions
Commenter Comment Response
benefits for low-income communities and Black,
Indigenous and Communities of Color.
Larry Hiscock Thank you for the opportunity to provide comment on
Environment Assessment Worksheet (EAW) for the
proposed Blake Road Station Development. I have been a
strong advocate for the METRO Green Line Extension for
over 10 years because of the potential to build a
competitive region through economic growth and
reducing inequities. A key opportunity to reduce
entrenched racial and economic disparities in our region is
through Equitable Transit Oriented Development.
Extensive work was done in the planning process to
engage environmental justice communities and make
recommendations to address regional disparities. I am
deeply concerned that the EAW does not provide
cumulative impact analysis of the potential benefits and
burdens experienced by “vulnerable populations” or
environmental justice communities.
The Environmental Assessment Worksheet (EAW) is
incomplete by not including a Cumulative Potential Effects
(CPE) analysis taking into consideration the economic,
social and environmental effects of the development on
minority-owned business, renters, low-to-moderate
income people, and people of color. Additionally, the EAW
does not consider the cumulative impact of both the Blake
Road Station development and the potential
redevelopment of 325 Blake Road site. The analysis should
look at benefits, burdens, impacts on social determinants
of health, displacement of existing businesses and future
See response above regarding public comment
opportunities, environmental justice, 325 Blake
Road and the need for an EIS.
Other comments not related to EAW
requirements will be addressed outside of the
environmental review process in a separate letter
to the commenters including affordability,
commercial uses and racial equity.
Blake Road Station Development B-18
Findings of Fact and Conclusions
Commenter Comment Response
displacement as a result of increased property values
along with mitigation measures.
The benefits of a $2 billions public investment in the
METRO Green Line must extend beyond creating private
value for property owners and amenities for individuals
that can afford to live near the line. A key justification for
the line was its ability to connect low- and moderate-
income people to employment centers, produce affordable
housing and build healthy communities accessible to all.
City of Hopkins is already experiencing gentrification and
the METRO Green Line Extension will accelerate the
process.
Questions and Requests for the Responsible Government
Unit:
1. How was input gathered from community and
specifically environmental justice communities in the
surrounding area? How many individuals from the
immediate community provided feedback on the EAW.
2. Formally, I request that a full environmental justice
analysis be conducted looking at the cumulative impacts
of this projects and nearby projects will have on social
determinants of health, benefits/burdens, future
displacement of existing businesses and residents as a
result of increased property values along with mitigation
measures.
3. An additional request is for more engagement of the
surrounding community that is directly impacted by this
development. Extending the comment period should be
included.
Blake Road Station Development B-19
Findings of Fact and Conclusions
Commenter Comment Response
4. Request: That the City of Hopkins and developers use
the Equitable Development Scorecard and/or the GARE
Racial Equity Tool to maximize benefits and mitigate
burdens for communities experiencing racial disparities.
5. The Hopkins 2040 Plan explicitly references equity,
inclusion and affordable housing strategies. What effort
will be made to ensure this development will advance
those goals?
6. This project alone will have a transformative impact on
the area and will have a catalytic effect on the surrounding
market. Another significant development is being
considered at 325 Blake Road. Will a full Environmental
Impact Statement be conducted? The significance of the
project appears to warrant additional analysis.
Blake Road Station Development
Findings of Fact and Conclusions
Appendix C
Permits and Approvals Required
Blake Road Station Development C-1
Findings of Fact and Conclusions
Permits and Approvals Required
Unit of Government Type of Application Status
Minnesota Department of Health Watermain permit To be applied for
Minnesota Department of Labor
and Industry
Plumbing permit To be applied for
Minnesota Department of
Natural Resources
Water appropriation permit To be applied for, if
needed
Minnesota Pollution Control
Agency
National Pollutant Discharge
Elimination System (NPDES) permit
To be applied for
Minnehaha Creek Watershed
District
Stormwater permit To be applied for
Hennepin County Right-of-way permit To be applied for
Driveway permits To be applied for
City of Hopkins Planned unit development (PUD)
and site plan approval
To be applied for
Rezoning To be applied for
Building permits To be applied for
Demolition permit To be applied for
Erosion control, grading, and
stormwater permit
To be applied for
Right-of-way permit To be applied for
EIS need decision In process
Traffic Impact Anlaysis In process; to be
updated as needed
through permitting and
PUD process
Preliminary and final plat To be obtained, if
needed
Blake Road Station Development Findings of Fact and Conclusions
Appendix D
Supplemental Wastewater Information
Blake Excelsior Estimated Flow based on SAC Determination Guidelines
Proposed Unit/SF SF SAC
Retail 19,000 3050 7
Residential 770 1 770
Total SACS 777
1SAC = 274 gpd 274
Maximum Total Estimated Flow (gpd)212898
Average - Factor of 4 (gpd)53225
Existing Unit/SF SF SAC
Retail 95,298 3050 31
Residential 0 1 0
Total SACS 31
1SAC = 274 gpd 274
Maximum Total Estimated Flow (gpd)8561
Average - Factor of 4 (gpd)2140