Star Lake Concerned Citizens Group | P.O. Box 41, Dent MN 56528 | 218-251-1975

TALKING POINTS – EAW COMMENTS

Below are several suggestions for commenting on the EAW and possible reasons for OTC to require an EIS.  Feel free to comment on just one or two of the following suggestions, or as many as you like. You are not limited to this list; all elements of the EAW are open for comment.

Your input matters.  If you have personal experiences, expertise, or fact-based information on any of the following EAW subject areas please submit a comment letter to OTC. 

Please be specific and reference, if possible, the sections of the EAW provide.  It is important to respond in your own words; do not just copy/paste the text from the talking point(s).

Link to OTC website to view the Star Lake Casino Development EAW:  Click Here

 

Talking Point:  EQB Rules and Guidance

The purpose of the EAW is a brief document designed to lay out the basic facts of a project necessary to determine if an EIS is required for the proposed project.  By definition, the scope of an EAW is limited and provides only an overview of environmental implications, while an EIS provides "... in-depth environmental analysis ..."

Comments that specifically address the scope and magnitude of potential adverse environmental effects of the total proposed project on extremely sensitive lakeshore will support the need for an EIS.

 

Talking Point:  EAW Item 6 (b) – Project Description (p. 3)

Per the EAW “The project will permanently convert former farmsteads, farmland, open space, and wetlands into a resort facility. The proposed project is a resort which will support indoor and outdoor pools, with a gaming facility, 180 guest room hotel, 216 seat Bar & Grill and 255 seat Buffet restaurants, 400 seat event center, supporting offices and storage spaces (in the main facility), RV Park for 25 overnight stays with a support building, and associated parking for automobiles and buses. In addition, there will be raw water well(s), potable water treatment and storage facilities and wastewater treatment ponds. The facility will operate 7 days a week, 24 hours a day, with a target demographic focusing on families.”

Comments that tie the size, scope, complexity and jurisdictional problems (state/county vs. federal permitting) to the need for an EIS can help build the case for a comprehensive environmental review of the TOTAL project.

 

Talking Point:  EAW Item #9 (b) Land Use Compatibility (p. 10)

Even with the rural character of the surrounding lands, the project is compatible with existing land use identified within the Limited Star Lake Comprehensive Plan (LASLCP) area boundary. Consider commenting on:

  1. If you attended any of the LASLCP public meetings, describe the process of public input gathering that you experienced, and whether or not you felt your views were represented by that process. Did that process allow for a ’no build” alternative? Do you feel that you’ve been told ‘it’s a done deal, so your input doesn’t matter?

  2. The “rural" character of our lake is noted in the Limited Area Star Lake Comprehensive Plan as being important to property owners and people in the area. Is that a concern of yours?  How would you define what is important to you about the “rural” character?  In your view, is this commercial development compatible with our area?

Link to OTC website to view information about the Limited Star Lake Comprehensive Plan:  Click Here

 

Talking Point: EAW Item 11 (b) (i) Water Resources > Wastewater (p. 18)

Proposed waste water treatment will be located adjacent to a “Natural Environment” lake that flows directly into Star Lake and on into Dead Lake.  

Topic for writing a comment letter demonstrating"need" for an EIS ... An EIS could allow for additional in depth scientific examination of consequences of the location of proposed sewage and waste-water treatment system.  The developers claim to meet minimum standards, but the failure of the process or any component could be catastrophic given its proposed location.  Are minimums appropriate in this location?

 

Talking Point:  EAW Item 11 (b) (iv) Water resources / Surface Waters / Alternatives (p. 26-27)

Applicable federal and state regulations require impacts to wetlands to be avoided and/or minimized. The EAW should identify potential project alternatives, reconfigurations or other changes that would be less intrusive to the environment.

If you know of or could propose alternative configurations or locations for the project that would further minimize adverse environmental impacts on Star Lake's wetlands, offer those observations in a comment letter.

 

Talking Point:  EAW Item 11 (b) (iv) Water resources / Surface Waters / Wetland Mitigation (p. 26-27)

The developer is required to explain the viability of locating required compensatory mitigation for unavoidable wetland impacts within the same minor or major watershed. The developers propose to dredge and fill 8.41 acres of Star Lake wetlands with 450,000 +/- cubic yards of fill, and substitute (trade) for 15 acres of wet land replacement in Becker and Roseau Counties.

Comments with facts challenging the mitigation compensation to Star Lake, or calling for the required additional scientific investigation of the impacts to Star Lake could be useful.

 

Talking Point:  EAW Item #15 Visual (p. 36)

Describe any scenic views or vistas on or near the project, or project related visual effects such as glare from intense lights. Consider writing a comment letter about:

  1. The EAW fails to take into consideration cumulative effect of numerous parking lot lights, and doesn’t mention the impact of lighting that is used to advertise the casino.  Are you concerned about the visual impact of these aspects of the Casino, the effect on the night sky, and/or the character of our area?  In your own words, describe your experience of the lake and how this might affect it.

  2. Do you access the lake from Highway 41? How would you feel about a highly visible wastewater treatment facility on the roadside just south junction of 41 and 380th street? Would that affect your experience of the lake?

 

Talking Point:  EAW Item #16 (c) Air > Dust and Odors (p. 37)

Twice per year it is anticipated there will be periods where odors from wastewater ponds are noticed.

If you have homes/cabins on 380th Street (Peterson Point) or the West arm, or hunt in the area in the fall, would odor from such a facility concern you? Is it compatible with the character of our lake?

 

Talking Point:  EAW Item #17 Noise (p. 38)

Residences are present to the north and east along the shores of Star Lake. Typical existing noise currently is from automotive and boating traffic on the roads and lakes.

Does additional noise concern you? If yes, please describe and explain why in your comment letter.

 

Talking Point:  EAW Item #18 (b) Transportation (p. 39)

While traffic increases (on County Highway 41) will likely be noticeable to local residents … traffic increases are not anticipated to significantly impact the local or regional transportation system).

  1. Do you agree with this statement? Where do you access CH-41?  What has been your experience of traffic at that juncture?  Do you notice a seasonable aspect to the traffic that may not be taken into consideration by this statement?

  2. It’s been suggested that County Highway 41 at the junction of State Highway 108 may be rerouted. The EAW fails to offer any studies of this connected action. If your cabin is on 41 or your family or friends use the Galaxy cabins, if you walk or jog or bicycle on 41, or if your family frequents the corner store, would additional traffic, up to 200 cars an hour, be a problem for you?  Would ‘dedicated turning lanes’ be enough to mitigate that increase in traffic?

 

Talking Point:  EAW Item #19 Cumulative Potential Effects (p. 40)

Cumulative potential effects.

  1. Is it likely this project will bring in other related developments that might affect the character of our area? Does that concern you?

  2. Were you at any of the Casino meetings where additional phases were discussed? What were those phases? Can you think of other cumulative effects? Does the cumulative effect of unprecedented and rapid development of our area concern you? Why?

 

Talking Point:  EAW Item 19 Cumulative Potential Effects (p. 40)

Potential future phased additions to the project which are not disclosed or analyzed.  The EAW requires an analysis of the impacts of related projects (including future projects actually planned or reasonably expected) which could have a "cumulative potential effect" (environmental).

If you attended Star Casino information meetings or have other knowledge of additional future additions, property uses and/or resort enhancements not disclosed in the EAW, these could potentially re-enforce the need for additional disclosure and environmental analysis.

 

Talking Point: Limited Area Star Lake Comprehensive Plan (LASLCP)

The “Limited Area Star Lake Comprehensive Plan” is cited as the basis for EAW conclusions and representations throughout the EAW. The “Plan” was specifically NOT adopted as a guide or plan by OTC.

Cite inconsistencies, inaccuracies or other deficiencies.  Such as LASLCP offers few if any specific solutions or ways of funding needed infrastructure, social or public safety requirements identified.  Future costs to OTC and taxpayers?

Link to OTC website to view information about the Limited Star Lake Comprehensive Plan:  Click Here