Environmental Assessment
Elm Avenue Diversion
City of Delano, Wright County, Minnesota
FEMA 1419-DR-MN
August 2005



This document was prepared by URS

200 Orchard Ridge Drive, Suite 101
Gaithersburg, Maryland  20878

Contract No.  EMW-2000-CO-0247
Task Order 311


List of Acronyms	iii

Section 1 Introduction	1-1
1.1	Project Authority	1-1
1.2	Project Location and Setting	1-1
1.3	Purpose and Need	1-1

Section 2 Alternatives Analysis	2-1
2.1	Alternative 1  No Action	2-1
2.2	Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet	2-1
2.3	Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet	2-1
2.4	Alternatives Considered But Dismissed	2-2

Section 3 Affected Environment and Environmental Consequences	3-1
3.1	Physical Environment	3-1
3.1.1	Geology, Seismicity, and Soils	3-1
3.1.2	Water Resources and Water Quality	3-2
3.1.3	Floodplain Management (EO 11988)	3-5
3.1.4	Air Quality	3-6
3.2	Biological Environment	3-7
3.2.1	Terrestrial and Aquatic Environment	3-7
3.2.2	Wetlands (EO 11990)	3-10
3.2.3	Threatened and Endangered Species	3-11
3.3	Hazardous Materials	3-12
3.4	Socioeconomics	3-13
3.4.1	Zoning and Land Use	3-13
3.4.2	Visual Resources	3-14
3.4.3	Noise	3-15
3.4.4	Public Services and Utilities	3-16
3.4.5	Traffic and Circulation	3-17
3.4.6	Environmental Justice (EO 12898)	3-18
3.4.7	Safety and Security	3-19
3.5	Cultural Resources	3-20
3.5.1	Tribal Coordination	3-21

Section 4 Cumulative Impacts	4-1

Section 5 Public Participation	5-1

Section 6 Mitigation Measures and Permits	6-1

Section 7 Consultations and References	7-1

Section 8 List of Preparers	8-1

Tables

Table 1	Demographic Information	3-18
Table 2	Impact Summary Matrix	3-22
Table 3	Permits and Mitigation by Alternative	9-1

Figures 

Figure 1	Regional Location
Figure 2	Project Location
Figure 3	Proposed Alternatives
Figure 4	FEMA Floodplains
Figure 5	Proposed HMGP Project Locations

Appendices

Appendix A	Project Area Photos
Appendix B	Agency Correspondence 
Appendix C	Best Management Practices
Appendix D	EO 11988 and EO 11990 Eight-Step Planning Process
Appendix E	Public Notice

ACRONYMS

APE		Area of Potential Effects
ASTM		American Society for Testing and Materials

BMP		Best Management Practice
BWSR		Board of Water and Soil Resources

CAA		Clean Air Act
CERCLA		Comprehensive Environmental Response, Compensation, and Liability Act
CEQ		Council on Environmental Quality
CFR		Code of Federal Regulations
CO		Carbon Monoxide
CWA		Clean Water Act

dB		decibel
DHS		Department of Homeland Security
DNL		Day/Night Average Sound Level

EA		Environmental Assessment
EDR		Environmental Data Resources
EIS		Environmental Impact Statement
EO		Executive Order
ESA		Endangered Species Act
EPA		Environmental Protection Agency

FEMA		Federal Emergency Management Agency
FHBM		Flood Hazard Boundary Map
FIRM		Flood Insurance Rate Map
FONSI		Finding of No Significant Impact

HMGP		Hazard Mitigation Grant Program
HWL		High Water Level

LGU		Local Governmental Unit
LUST		Leaking Underground Storage Tank

MDNR		Minnesota Department of Natural Resources
MNRRA		Mississippi National River and Recreation Area
MPCA		Minnesota Pollution Control Agency
MRCA		Mississippi River Critical Area

NAAQS		National Ambient Air Quality Standards
NCA		Noise Control Act of 1972
NEPA		National Environmental Policy Act
NHP		Natural Heritage Program
NISTAC		Nationwide Infrastructure Technical Assistance Consultants
NFIP		National Flood Insurance Program
NO2		Nitrogen Dioxide
NPDES		National Pollution Discharge Elimination System
NPS		National Park Service
NRHP		National Register of Historic Places
NWI		National Wetland Inventory

O3		Ozone
OSA		Minnesota Office of the State Archaeologist
OSHA		Occupational Safety and Health Administration

PA		Public Assistance
Pb		Lead
PM10		Particulate Matter of 10 microns or less

RCRA		Resource Conservation and Recovery Act
ROW		Right-of-Way

SF		Square Feet
SHPO		State Historic Preservation Office
SO2		Sulfur Dioxide
SWA		Solid Waste Act

TMDL		Total Maximum Daily Load
TSCA		Toxic Substance Control Act

USACE		United States Army Corps of Engineers
USDA		United States Department of Agriculture
USFWS		United States Fish and Wildlife Service
UST		Underground Storage Tank

WCA		Wetland Conservation Act
WSRA		Wild and Scenic Rivers Act


Section 1 Introduction

1.1 PROJECT AUTHORITY
On six occasions during 2001 and 2002, the City of Delano (the City) was forced to conduct 
emergency pumping and sandbagging activities to mitigate flooding adjacent to County Line 
Pond. Despite sandbagging efforts, the basements of many homes flooded. On three of the six 
occasions, the sanitary sewer system also backed up as a result of the flooding, affecting 
additional homes downstream. 

The City of Delano, Wright County, Minnesota, applied for Hazard Mitigation Grant Program 
(HMGP) funding under Section 406 of the Robert T. Stafford Disaster Relief and Emergency 
Assistance Act after the 2002 flooding. The Federal Emergency Management Agency (FEMA) 
grants funds under this program for mitigation measures, projects, or actions proposed to reduce 
risk of future damage, hardship, loss of suffering from future disasters. In accordance with the 
National Environmental Policy Act (NEPA) of 1969, the Council on Environmental Quality 
(CEQ) regulations implementing NEPA (40 Code of Federal Regulations [CFR] Parts 1500 
through 1508), and FEMA regulations for NEPA compliance (44 CFR Part 10), FEMA must 
fully understand and consider the environmental consequences of actions proposed for Federal 
funding. The purpose of this Environmental Assessment (EA) is to meet FEMAs responsibilities 
under NEPA and to determine whether to prepare a Finding of No Significant Impact (FONSI) 
or an Environmental Impact Statement (EIS) for the proposed project. 

1.2 PROJECT LOCATION AND SETTING
The City of Delano is in Wright County, approximately 25 miles west of the Minneapolis-St. 
Paul Metropolitan area in east central Minnesota (Figure 1). The County is bordered on the north 
by the Mississippi River and on the east by the Crow River. The project site is located in the City 
of Delano, which lies along the Crow River in the southeastern part of the County. Delano has a 
population of 3,847 (U.S. Census, 2000). The project is proposed to be located in a residential 
neighborhood near the intersection of Elm Avenue and Oak Ridge Drive on the east side of the 
City, around and downstream of a low-lying area known as County Line Pond. County Line 
Pond does not hold water at all times, but is a basin that intermittently collects water during 
storm events (see project area photographs in Appendix A).

The homes in this residential subdivision are ranch-style homes built in the 1970s. These homes 
surround County Line Pond on the east, west, and south. Similar homes also line the south side 
and some of the north side of Elm Avenue. Delano High School borders the project site to the 
northwest (Figure 2).

1.3 PURPOSE AND NEED
The objective of FEMAs HMGP is to assist the community in mitigating conditions that could 
cause damages during future natural disasters. The City has requested Federal funding under 
HMGP to increase storm sewer capacity and provide a storm outlet for County Line Pond, to 
protect surrounding homes from flooding and to relieve sanitary sewer backup. The project also 
includes an emergency overflow from the pond to nearby Elm Avenue. 

The City was subject to six major storm events in 2001 and 2002, causing the flooding of County 
Line Pond. Despite sandbagging efforts, 19 homes surrounding the pond experienced flooded 
basements. The City of Delano reports that average property damage in the 2002 storms was 
$20,000, or approximately 15 percent of the property value of any given home. The City also 
spent an average of $10,000 during each of the storm events in 2001 and 2002 to provide 
emergency pumping and sandbagging. In several cases, such as the storm event on June 24, 
2002, the emergency pumping did not relieve damage to private property.

In the past, flooding of County Line Pond has also resulted in sanitary sewer backup. The City 
instituted an inspection program to find and eliminate sump pump connections into the sanitary 
sewer, and also replaced a number of manhole covers in flood-prone areas to reduce the amount 
of floodwaters entering the sanitary sewer system through manholes. However, the City has 
determined that flooded basements also contribute to sanitary sewer problems. Floodwater enters 
basements and infiltrates the separate sanitary sewer system through shower and basement 
drains. This exceeds system capacity, forcing sewage and contaminated waters out into the 
basement. The flooding of County Line Pond resulted in sanitary sewer backups on one occasion 
in 2001 and two occasions in 2002. These backups affected approximately 20 homes 
downstream of the pond, resulting in a wide range of property damage amounts. One homeowner 
reported over $45,000 in damage to a finished basement due to the backup of the sanitary sewer 
system. In addition to property damage, sanitary sewer system backup poses a significant and 
widespread health and safety risk to residents when raw sewage backs up into their homes. 
Therefore, improvement of the storm sewer system will also address the sanitary storm sewer 
issues in the project area.

The purpose of and need for the proposed project is to increase storm sewer capacity and provide 
a storm outlet for County Line Pond, to protect surrounding homes from flooding and to relieve 
sanitary sewer backups. 

The CEQ has developed regulations for implementing NEPA. These Federal regulations require 
an evaluation of alternatives and a discussion of the potential environmental impacts of a 
proposed Federal action as part of the EA process. FEMA regulations, which establish the 
FEMA process for implementing NEPA, are set forth in 44 CFR, Subpart 10. This EA was 
prepared in accordance with FEMA regulations as required under NEPA. As part of this NEPA 
review, the requirements of other environmental laws and Executive Orders (EOs) are also 
addressed.


Section 2 Alternatives Analysis

2.1 ALTERNATIVE 1  NO ACTION
Under the No Action Alternative, improvements would not be made to the existing storm sewer 
or outlets to County Line Pond. During major storm events, residents would continue to 
experience flooded basements and extensive property damage. Health and safety risks for area 
residents as a result of sanitary sewer backup into homes would also remain.

2.2 ALTERNATIVE 2  ELM AVENUE DIVERSION AND INCREASE SIZE OF POND 
OUTLET (PREFERRED ALTERNATIVE)
Alternative 2 involves installation of 1,900 linear feet of 24- to 36-inch piping to provide a 10-
year storm outlet for County Line Pond (Figure 3). The project also includes an emergency 
overflow to the northwest from the pond to Elm Avenue. The project would reduce the high 
water level (HWL) by 4.3 feet (from 952.2 feet to 947.9 feet) during a 100-year storm event 
(Bonestroo, 1997).

The Elm Avenue Diversion would include construction of a larger outlet to County Line Pond, 
upgrade of storm sewer piping in Elm Avenue, and installation of a storm sewer diversion from 
Elm Avenue to the area south of Delano High School, approximately 0.3 mile northwest of the 
County Line Pond. A 24-inch pipe would replace the 12-inch pipe that currently provides an 
outlet from the north edge of the pond to Elm Avenue. This larger pipe would reduce the HWL 
by 4.3 feet to 947.9 feet.  This pipe would connect to a new 36-inch pipe running on the south 
side of Elm Avenue west to Oak Ridge Drive. Some of the water would then be diverted across 
Elm Avenue to the north via a 24-inch pipe, while the remaining water would continue along the 
existing 18-inch storm sewer in Elm Avenue.  The diversion would outlet into an existing 
wetland (Wetland 1), with a HWL in the wetland of 945.4 feet. Wetland 1 would outlet to a 24-
inch pipe, which would lead to a second wetland (Wetland 2) to the northwest where the HWL 
would be 942.3 feet. Wetland 2 would outlet to a 36-inch pipe leading directly west along the 
south side of Delano High School, where it would eventually outlet into the existing 18-foot by 
4-foot drainage ditch (Figure 3).

As part of construction, all vegetation would be cleared along the utility line. Vegetation will be 
replaced with species similar to existing conditions. No dewatering is planned for this project. 
Storage of construction equipment and materials would take place at the Delano High School 
property, which borders the project site. No classes or activities are planned for the high school 
in the summer months. Scheduled summer classes take place at another school site, and there are 
no organized sports practices or events scheduled to take place on-site in the summer months 
(Farbo, personal communication). The bulk of project construction would take place in the 
summer months when school classes are not in session; therefore school activities would not be 
disrupted. 

The City would ensure that one lane of Elm Avenue remains open to traffic at all times during 
construction. The portion of the project that requires disruption to traffic on Elm Avenue would 
only last one day. The entire project is anticipated to require up to five months to complete, and 
the planned completion date is September 2006.

2.3 ALTERNATIVE 3  TWO DIVERSIONS FROM ELM AVENUE AND INCREASE SIZE OF POND OUTLET
Alternative 3 includes installation of piping and an emergency overflow as described in 
Alternative 2.  In addition, Alternative 3 includes a second diversion from the proposed storm 
sewer on Elm Avenue. This second diversion would occur just west of the entrance road to 
Delano High School, and would be approximately 280 feet in length (Figure 3). New 30-inch 
pipe would connect directly into the proposed 36-inch pipe that would connect to the existing 
storm sewer system. This alterative would provide slightly higher reductions in street flooding 
and HWL compared to Alternative 2. However, Alternative 3 would also require additional pipe 
installation, additional tree removal, and additional easements from the high school. As part of 
construction, all vegetation would be cleared along the utility line. No dewatering is planned for 
this project. 

Storage of construction equipment and materials would occur on Delano High School property, 
which borders the project site. The bulk of construction would take place during the summer 
when school is not in session; therefore school activities would not be disrupted.

The City would ensure that one lane of Elm Avenue remains open to traffic at all times during 
construction. The portion of the project which requires disruption to traffic on Elm Avenue 
would only last one day. The entire project is anticipated to require up to five months to 
complete, and the planned completion date is September 2005.

2.4 ALTERNATIVES CONSIDERED BUT DISMISSED
The enlargement of County Line Pond and the replacement of storm sewer on Elm Avenue was 
also considered as an alternative to this project.  However, this alternative was dismissed because 
it would require additional excavation and would significantly increase project cost and 
environmental effects. 

The City of Delano also considered installing pipe larger than 36 inches in diameter on Elm 
Avenue. However, this alternative was dismissed because it would require large amounts of 
street repair on Elm Avenue. This would result in a longer period of construction on Elm 
Avenue, which would disrupt traffic and area residents for a longer period of time, and result in 
higher project costs

Section 3 Affected Environment and Environmental Consequences

3.1 PHYSICAL ENVIRONMENT

3.1.1 Geology, Seismicity, and Soils
The physical relief in the region that includes the project area was formed by pre-Wisconsin 
glaciation, resulting in outwash plains, gently rolling to steep hills, and numerous depressions 
filled with marshes, wetlands, and lakes. The South Fork of the Crow River bisects the City of 
Delano, creating a well-defined river valley. The City is largely situated on a relatively flat 
floodplain, though the project area is outside of the 100-year floodplain.

Bedrock underlying the project area is primarily composed of Cambrian and Precambrian 
sedimentary rock formations, consisting of sandstone, shale, and dolomite in upper layers, and 
sandstone, siltstone, and shale in lower layers. Bedrock is overlain with undifferentiated drift, 
which is primarily gray, calcareous, silty till that is largely unsorted and unstratified. There may 
be buried sand and gravel deposits of varying extents (Wenck Associates, 2004).

Soils within the City of Delano area are mapped entirely within the Hayden-Lester-Peat 
association, which is described as deep, medium-textured and moderately fine-textured soils on 
strongly rolling and hilly uplands (USDA, 1968).  Soils in the project area consist mostly of 
gentle to moderately sloping soils from the Hayden series. These soils are well to moderately 
well-drained with a loam surface soil and clay loam subsoil. In some of the lower-lying areas, 
such as along Elm Avenue and around wetland areas, the soil type is Glencoe silty clay loam. 
This is a poorly drained, seasonally ponded soil with a high organic content.

Alternative 1  No Action
The No Action Alternative would not result in any construction impacts to geology, seismicity, 
and soils. However, with no storm sewer diversion, sanitary sewer backup would continue to be 
a problem in the Elm Avenue area. Raw sewage could infiltrate the soil and cause contamination.

Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Alternative 2 may result in soil erosion at the end of the proposed new piping, at the drainage 
ditch.  This erosion would be caused by increased water speeds resulting from diverting water 
through the proposed new piping. To decrease water velocity and therefore reduce erosion 
impacts, size-appropriate riprap would be used at the pipe outlet. Silt fencing may also be used 
when heavy rainfall events are anticipated.

The use of required Best Management Practices (BMPs) would include protecting erodible 
surfaces (see Appendix C). Earthwork would not be allowed during precipitation events. 
Additionally, exposed soils would be seeded with a mix comparable to what currently exists. 
Construction specifications would identify the specific seed mix to be used by the contractor. In 
addition, compacted soils would be loosened by disking or raking prior to seeding.

Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet
Alternative 3 may also result in soil erosion at the end of the proposed new piping, at the 
drainage ditch, as described under Alternative 2.  This erosion would be magnified over that 
caused by Alternative 2, because of the second diversion and the increase in the volume of water 
directed to the ditch. As described under Alternative 2, size-appropriate riprap would be used at 
the pipe outlet. Silt fencing may also be used when heavy rainfall events are anticipated.
Construction activities such as pipe excavation, grading and travels of construction equipment to 
and from the site may result in a temporary increase in surface soil erosion and compaction. This 
disturbance would be in excess of Alternative 2, as Alternative 3 would require additional 
excavation (560 additional cubic yards over Alternative 2) and grading. This would be 
minimized through the use of BMPs as described under Alternative 2.

3.1.2 Water Resources and Water Quality

As part of the Clean Water Act (CWA) Sections 404 and 401, each State is required to prepare a 
biennial report for the Environmental Protection Agency (EPA) on the quality of its water 
resources. States may measure water quality through a number of parameters, including 
examining fish and wildlife contaminants, water and sediment chemistry, biological 
integrity/physical habitat, and stream flow. The goal of the CWA is to achieve waters suitable for 
fishing and swimming. This is assessed in terms of aquatic life, aquatic consumption, and aquatic 
recreation. 

Minnesotas 2004 Water Quality Report states that the 31.4-mile stretch of the South Fork of the 
Crow River from Buffalo Creek to the North Fork of the Crow River, which includes the project 
area, is listed as not supporting the aquatic life and aquatic consumption assessment criteria. It 
was not evaluated for aquatic recreation. The indicators of impairment for this stretch of river 
include fish, turbidity, and mercury. This stretch of the river also exceeds ecoregion norms for 
total phosphorus, nitrite/nitrate, oxygen demand, and suspended solids (MPCA, 2004).

As a result, this segment of the river is on the Impaired Waters List under Category 5A. Under 
Category 5, the water body does not meet applicable water quality standards or is threatened for 
one or more designated uses by one or more pollutants. Historically, agricultural runoff and 
faulty septic systems/wastewater treatment systems have been the primary causes of water 
pollution in this region. 

Potential water quality impacts as a result of any new project construction generally originate 
from the following:
-Erosion of exposed soils during construction;
-Reduced infiltration and increased runoff from the construction of new impervious surfaces;
-Pollutants from automobiles, such as oil, grease, and metals, that collect on impervious 
surfaces and are washed off by stormwater runoff;
-Increased stormwater runoff that overburdens existing drainage systems, causing 
flooding; and,
-Fill or construction in floodplains, which affects flood levels in streams and rivers.

Both the Minnesota Department of Natural Resources (MDNR) Waters Division and the United 
States Army Corps of Engineers (USACE) were sent information describing and illustrating the 
proposed project. In an e-mail dated October 13, 2004, Patricia Fowler, MDNR Area 
Hydrologist, indicated that the proposed project does not impact any public waters of the state, 
and MDNR authorization is not required. She noted that a MDNR Water Appropriation Permit 
would be required if proposed construction dewatering would exceed 10,000 gallons per day or 
one million gallons per year (see Appendix B). The proposed project alternatives would not 
require dewatering. The MDNR did not voice any concerns about impacts to the South Fork of 
the Crow River.

USACE also reviewed the project and did not voice any concerns about impacts to the South 
Fork of the Crow River (see Appendix B). Wetlands are addressed in Section 3.2.2.

The proposed project would not increase the amount of impervious surface and would, in fact, 
help to decrease the overburden on existing drainage systems that currently results in flooding 
and septic system backup during significant storm events. Erosion of exposed soils would be 
managed by BMPs as described in Section 3.1.1.

Potential sedimentation due to temporary construction impacts is discussed below. The proposed 
project does impact wetlands, which are discussed in Section 3.2.2. 

Special Designation Areas
The U.S. Congress added the Mississippi National River and Recreation Area (MNRRA) to the 
National Park Service (NPS) system in 1988 (Public Law 100-696). The MNRRA boundary 
includes 54,000 acres of river and adjoining land along a 72-mile stretch of the Mississippi 
River. The State of Minnesota also designated the Mississippi River corridor as a Critical Area in 
1976 in State EO No. 79-19.  The Mississippi River is located outside the study area. No further 
action is necessary under the MNRRA designation. 

Within the State of Minnesota, there is one federally designated Wild and Scenic River, the St. 
Croix River, under 16 USC Section 1273, the Wild and Scenic Rivers Act (WSRA) (NPS, 2003). 
The St. Croix River is located outside the study area. The State of Minnesota has also developed 
a State-designated Wild and Scenic River program. A stretch of the Mississippi River from St. 
Cloud to Anoka is part of the Wild and Scenic River District. This is also located outside the 
study area. No further action is necessary under the WSRA or under the State-designated Wild 
and Scenic River program.

Alternative 1  No Action
Under the No Action Alternative, periodic flooding and sanitary sewer backup during heavy 
rainfall events would still occur. Residents would continue to be at risk from raw sewage 
infiltrating the storm sewer and potentially reaching surface waters and drinking water supplies. 
Continued flooding would also result in increased erosion and sedimentation of water bodies.
 
Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Alternative 2 does not lie within any streams, lakes, or rivers.  However, stormwater diverted 
from County Line Pond will eventually drain into the South Fork of the Crow River, as it does 
under existing conditions.  The Elm Avenue Diversion would direct stormwater to the river more 
quickly, but overall would not impose pollution or long-term sedimentation on the South Fork of 
the Crow River. In fact, the risk of sedimentation from erosion, and the risk of water pollution 
from backed up sanitary sewers would be reduced by this alternative.

Alternative 2 has the potential for minor impacts on water quality as a result of construction 
grading, which may cause temporary sedimentation of sewer systems due to erosion of bare 
soils. It is possible but unlikely that this sedimentation would reach the South Fork of the Crow 
River, as the water would be treated in a series of ponds as it works its way through the 
remaining storm sewer system before reaching the river. BMPs for erosion control during 
construction would be implemented as outlined in stormwater and erosion control plans. BMPs 
may include protecting erodible surfaces and avoiding construction during precipitation events. 
The City of Delano has an approved Stormwater Management Plan, which outlines BMPs that 
are required through city ordinance. The following ordinances are cited in the plan and have 
BMP provisions for protecting water resources and water quality (Bonestroo, 1997):
-Grading, Erosion, and Sediment Control Ordinance
-Wetland Systems District Ordinance
-Floodplain District Ordinance

Each of these ordinances would be adhered to during project construction. A National Pollution 
Discharge Elimination System (NPDES) permit is required, as the project would involve more 
than one acre of grading. The City has initiated this permit process by preparing a Stormwater 
Pollution Prevention Plan (SWPPP), which lists the BMPs that would be used as part of the 
project, and how and when the BMPs will be implemented. The plan states the BMPs would all 
be in place prior to any excavation/construction, and would be maintained until viable turf or 
ground cover has been established. BMPs included in the SWPPP are:
-Rock construction entrance
-Erosion control blankets (Bioroll blanket system)
-Silt fence
-Inlet sediment filters

The City has initiated preparation of this plan, and will submit the plan to the selected contractor. 
The BMP detail sheets that would be included in the SWPPP are included in Appendix C. It 
would be the contractors responsibility to use the SWPPP information to submit an NPDES 
permit to the Minnesota Pollution Control Agency (MPCA). This would be submitted 48 hours 
prior to construction, as mandated in permit requirements. The permit acts as a notification so the 
MPCA can monitor the project. 

Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet
Alternative 3 has the potential for minor impacts on water quality as a result of construction 
grading, which may cause temporary sedimentation of sewer systems due to erosion of bare 
soils. BMPs for erosion control during construction would be implemented as described above 
under Alternative 2. An NPDES permit is also required for this Alternative.
Alternative 3 would also reduce the risk of sedimentation and pollution caused by flooding and 
sanitary sewer backup.

3.1.3 Floodplain Management (EO 11988)
Floodplain refers to the 100-year floodplains as defined by FEMA.  They are shown on Flood 
Insurance Rate Maps (FIRMs) or Flood Hazard Boundary Maps (FHBMs) for all communities 
participating in the National Flood Insurance Program (NFIP).
The 100-year floodplain designates the area inundated during a flood that has a one percent 
chance of occurring in any given year. FEMA also identifies the 500-year floodplain, which 
designates the area inundated during a flood that has a 0.2 percent chance of occurring in any 
given year.

EO 11988 directs Federal agencies to take action to minimize occupancy of and modification to 
floodplains. Specifically, EO 11988 prohibits FEMA from funding construction in the floodplain 
unless there are no practicable alternatives. FEMA regulations for complying with EO 11988 are 
promulgated in 44 CFR Part 9. FEMA applies the Eight-Step Planning Process as required by 
regulation to meet the requirements of EO 11988 (see Appendix D).

The project would not occupy the 100-year floodplain (see Figure 4), however stormwater from 
the proposed project would eventually reach the floodplain of the South Fork of the Crow River. 
Both the Minnesota Department of Natural Resources (MDNR) Waters Division and the United 
States Army Corps of Engineers (USACE) were sent information describing and illustrating the 
proposed project. In an e-mail dated October 13, 2004, Patricia Fowler, MDNR Area 
Hydrologist, indicated that the proposed project does not impact any public waters of the state, 
and MDNR authorization is not required. The MDNR did not voice any concerns about impacts 
to the South Fork of the Crow River or the 100-year floodplain.

USACE also reviewed the project and did not voice any concerns about impacts to the South 
Fork of the Crow River or the 100-year floodplain (see Appendix B). Wetlands are addressed in 
Section 3.2.2.

Alternative 1  No Action
No occupancy or direct modification to the 100-year floodplain would occur; therefore, EO 
11988 is not applicable. 

Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Alternative 2 would not occupy or directly modify the 100-year floodplain.  The project would, 
however, reduce the time that it takes for water to reach the floodplain by providing a more 
efficient outlet system for County Line Park Pond and an unnamed ponding area (HS=P610 per 
the Citys Stormwater Management Plan).  The upstream watershed of the South Fork of the 
Crow River is approximately 1,200 square miles (768,000 acres).  The proposed Alternative 2 
improvements would impact a watershed that is approximately 50 acres (County Line Park Pond 
and HS=P610).  Thus, the watershed affected by the proposed project is less than 0.01 % of the 
upstream watershed.  Based on this analysis, the proposed project will not impact the elevation 
of the 100-year flood of the South Fork of the Crow River.  

Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet
Alternative 3 would not occupy or directly modify the 100-year floodplain.  The project would, 
however, reduce the time that it takes for water to reach the floodplain by providing a more 
efficient outlet system for County Line Park Pond and an unnamed ponding area, HS=P610 per 
the Citys Stormwater Management Plan.  Based on the analysis described under Alternative 2, 
Alternative 3 will not impact the elevation of the 100-year flood of the South Fork of the Crow 
River.  

3.1.4 Air Quality
The Clean Air Act of 1970 (CAA), as amended, requires the Environmental Protection Agency 
(EPA) to set National Ambient Air Quality Standards (NAAQS) for pollutants considered 
harmful to public health and the environment. The CAA establishes two types of national air 
quality standards: primary and secondary. Primary standards set limits to protect public health, 
including the health of sensitive populations such as asthmatics, children, and the elderly. 
Secondary standards set limits to protect public welfare, visibility, and damage to animals, crops, 
vegetation, and buildings.

The EPA Office of Air Quality Planning and Standards has set NAAQS for six principal 
pollutants, which are called criteria pollutants: sulfur dioxide (SO2), nitrogen dioxide (NO2), 
carbon monoxide (CO), lead (Pb), particulate matter of 10 microns or less (PM10), and ozone 
(O3). 

The EPA has designated specific areas throughout Minnesota as NAAQS attainment or non-
attainment areas. Non-attainment areas are those that either do not meet, or contribute to ambient 
air quality in a nearby area that does not meet, the national primary or secondary air quality 
standards for a pollutant. According to the EPA, Wright County is in attainment for all six 
criteria pollutants (EPA, 2003).

Alternative 1  No Action
No construction activities would take place under this alternative; therefore, there would be no 
impact to air quality.

Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Implementation of Alternative 2 would involve limited use of heavy construction equipment, 
such as a backhoe, equipment trucks, and a skid steer. The duration of the proposed project 
activities is anticipated to be approximately five months.

Heavy construction equipment is a source of fugitive dust emissions that may have a temporary 
effect on air quality. Emissions occurring during construction would be associated with earth-
moving (grading). Dust emissions can vary from day-to-day, depending on the level of activity, 
the specific operations, and weather. Emissions from fuel-burning internal combustion engines 
(heavy equipment and earth-moving machinery) could temporarily increase the levels of volatile 
organic compounds and some of the priority pollutants, including CO, NO2, O3, and PM10.
To mitigate for potential air quality impacts from fugitive dust and equipment emissions, vehicle 
engines would be kept in good repair and turned off while not in use, and the project area would 
be watered in dry conditions. The same measures would also be taken in the identified 
construction staging areas.

Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet 
Implementation of Alternative 3 would involve limited use of heavy construction equipment, as 
described above under Alternative 2. The duration of the proposed project activities is 
anticipated to be approximately five months.

Heavy construction equipment is a source of fugitive dust emissions that may have a temporary 
effect on air quality. Emissions occurring during construction would be associated with earth- 
moving (grading). Dust emissions can vary from day-to-day, depending on the level of activity, 
the specific operations, and weather. Emissions from fuel-burning internal combustion engines 
(heavy equipment and earth-moving machinery) could temporarily increase the levels of volatile 
organic compounds and some of the priority pollutants, including CO, NO2, O3, and PM10.
Mitigation measures to control fugitive dust emission would be the same as those described 
under Alternative 2.

3.2 BIOLOGICAL ENVIRONMENT

3.2.1 Terrestrial and Aquatic Environment
Terrestrial Environment
The proposed project site includes the areas immediately adjacent to and above the path of the 
pipe that would be installed. 

A biologist with URS Group performed a site visit on September 17, 2004. The proposed pipe 
installation would originate from County Line Pond, which is located behind several homes. The 
pond does not normally hold much water, and is predominantly vegetated with reed canary grass 
(Phalaris arundinaceae) and cattail (Typha spp.), and is surrounded by mown grass. Vegetation 
along the north side of Elm Avenue includes American elm (Ulmus americana), box-elder (Acer 
negundo), and wood nettle (Laportea canadensis). Many of the species present within the 
proposed project site are invasive and/or not native to the area.  The path the proposed pipe 
would take leading to Wetland 1 includes jewelweed (Impatiens capensis), stinging nettle 
(Urtica dioica), and sumac (Rhus sp.). Wetland 1 consists of cattail, stinging nettle, jewelweed, 
and Canada thistle (Cirsium arvense), surrounded by reed canary grass. At the time of the site 
visit, no water was observed in Wetland 1. The depth of Wetland 1 appears to be very shallow at 
approximately one foot. Wetland 2 consists of stinging nettle, Canada thistle, and reed canary 
grass.  This area also contained no water and appeared relatively flat. Other areas within the 
proposed project site contain American elm, box-elder, and mown grass.

Wildlife that may use the project site include mammals such as white-tailed deer  (Odocoileus 
virginianus), Eastern cottontail rabbit (Sylvilagus floridanus), gray squirrel (Sciurus carolinesis), 
and raccoon (Procyon lotor), which likely use the site for movement between wooded areas. 
Songbirds will move through the area as habitat is suitable. Various songbirds were the only 
wildlife observed during the site visit.

Aquatic Environment
The proposed project does not lie near or within any streams, lakes, or rivers, and therefore no 
fish are present. The proposed project does impact wetlands, which are classified as seasonally 
flooded (Type 1) to shallow marsh (Type 3).  These areas likely provide temporary aquatic 
habitat, primarily in the spring, to species such as wood ducks, amphibians (frogs, toads, and 
salamanders), reptiles (snakes and turtles), and songbirds. Wetland impacts are discussed in 
Section 3.2.2. 

Alternative 1  No Action
Under this alternative, no changes to the existing terrestrial or aquatic environment would occur. 

Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Terrestrial Environment
The effects of Alternative 2 would include temporary disturbances to terrestrial habitat during 
project implementation. Existing trees and shrubs along the route of pipe installation would be 
removed to complete this alternative. It is not anticipated that any vegetation would be removed 
from construction staging sites as a result of the proposed project.
Trees and other vegetation would be replaced to the extent that access to the pipe can still be 
obtained. Native grass and forb species would be planted within the project site following project 
construction.

Effects to the terrestrial environment would be temporary until vegetation becomes reestablished. 
The incidental take of wildlife could be minimized by removing tree and shrub vegetation prior 
to April 1 and/or after July 15, to avoid migratory bird nesting periods. Heavy construction 
equipment would compact soils in the project area and potentially in construction staging areas. 
Soils compacted by construction machinery would be loosened by methods such as disking or 
raking. Overall, the terrestrial environment would be enhanced by the reintroduction of 
native/non-invasive species within the utility corridor.

Aquatic Environment
Temporary impacts to aquatic habitats would occur. These impacts would last for the duration of 
construction and would include removal of vegetation (habitat). Long-term impacts on the 
aquatic environment would likely include a more consistent water regime, because water is being 
sent to the wetlands more frequently through the improved storm sewer system. Although the 
wetlands would still be intermittently without water, the periods where surface water is present 
would be for a longer duration than what exists currently. This change is not anticipated to have 
negative consequences on aquatic resources.

Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet 
Terrestrial Environment
The effects of Alternative 3 would include temporary disturbances to terrestrial habitat during 
project implementation. Existing trees and shrubs along the roadways would be removed to 
complete this alternative. It is not anticipated that any vegetation would be removed from 
construction staging sites as a result of the project. Trees and other vegetation would be replaced 
as described under Alternative 2.

Heavy construction equipment would compact soils in the project area and potentially in 
construction staging areas. Soils compacted by construction machinery would be loosened by 
methods such as disking or raking. Overall, the terrestrial environment would be enhanced by the 
reintroduction of native/non-invasive species within the majority of the utility corridor. The area 
of the second diversion would be reseeded with turf grass, as currently exists.

Aquatic Environment
Temporary impacts to aquatic habitats would occur. These impacts would last for the duration of 
construction and would include removal of vegetation (habitat). Long-term impacts on the 
aquatic environment would likely include a more consistent water regime, as noted in Alternative 
2.  This change is not anticipated to have negative consequences on aquatic resources.
Temporary impacts to the aquatic environment would be minimized by implementing the 
measures described under Alternative 2.

3.2.2 Wetlands (EO 11990)
A wetland is defined by State and Federal regulations as an area that exhibits three distinct 
characteristics: 1) hydric soils; 2) inundation or saturation at or near the ground surface for a 
period of the growing season; and, 3) a prevalence of vegetation adapted to wet soil conditions. 
Wetlands are recognized as having important functions, including flood storage, water quality, 
wildlife and fisheries habitat, vegetation diversity, shoreland protection, aesthetics, and public 
recreation, resulting in their protection by local, State, and Federal regulations. These regulations 
require that wetland impacts be avoided or minimized to the extent feasible, with wetland 
replacement required for unavoidable impacts. Impacts that are unavoidable must be replaced at 
a ratio of at least two acres of wetland creation or restoration for every acre of wetland impact.
Under EO 11990, Federal agencies are required to minimize the destruction, loss, or degradation 
of wetlands and preserve and enhance their natural and beneficial values. If a Federal action has 
the potential to impact jurisdictional waters of the United States as defined by Section 404 of the 
Federal Clean Water Act (CWA), the U.S. Army Corps of Engineers (USACE) is contacted for 
appropriate permitting requirements. Section 404 of the CWA authorizes the USACE to issue 
permits, after notice and opportunity for public hearings, for the discharge of dredged or fill 
material into waters of the United States at specified disposal sites. The Minnesota Department 
of Natural Resources (MDNR) has regulatory authority over activities within selected wetlands 
and waters, as identified on Public Waters Inventory maps, published by the MDNR. The City of 
Delano has regulatory authority for all wetlands within its legal boundary.
FEMA applies the Eight-Step Planning Process as required by regulation to meet the 
requirements of EO 11990. This step-by-step analysis is included in Appendix D of this 
document. 

In 1991, the State of Minnesota enacted the Wetland Conservation Act (WCA). This legislation 
authorized Local Governmental Units (LGUs) to administer State wetland regulations. The WCA 
requires that activities resulting in the draining or filling of a wetland must be avoided or 
minimized. Impacts that are unavoidable must be replaced at a 2:1 ratio. At least the first 1:1 
must be creation of new wetland or purchase of wetland bank credits. The remaining 1:1 can be 
in the form of plantings or other creative mitigation (MDNR-approved fishing areas, habitat 
improvements, etc.) on the site. The WCA is administered by the Board of Water and Soil 
Resources (BWSR) and implemented by LGUs. In those cases where wetland impacts occur on 
State land, the LGU is the State agency with administrative responsibility for that land.
Wetlands were identified using National Wetland Inventory (NWI) mapping and verified during 
a site visit on September 17, 2004. There are two NWI designated wetlands within the project 
area, both classified as Palustrine, Emergent, and Seasonally Flooded (PEMC)/Type 3, or 
shallow marsh.  Field review of the site by the URS biologist identified Wetland 1 as 
PEMC/Type 3 and Wetland 2 as Palustrine, Emergent, and Temporarily Flooded (PEMA)/Type 
1, or seasonally flooded basin. Water was not observed in either of the wetlands during the site 
visit. The wetlands appeared as shallow depressions (two feet in depth or less) with little capacity 
for water storage. Typical vegetation included cattails in Wetland 1 and grasses and forbs in 
Wetland 2. The location of these wetlands is shown on Figure 3.

The ditch portion of County Line Pond also meets wetland criteria. The ditch contains cattails 
and willow vegetation, and shallow to deep water during storm events. The ditch is identified by 
URS as PEMC/Type 3, or shallow marsh. County Line Pond is also shown on Figure 3.
Both the MDNR Waters Division and the USACE were sent information describing and 
illustrating the proposed project. In an e-mail dated October 13, 2004, Patricia Fowler, MDNR 
Area Hydrologist, indicated that the proposed project does not impact any public waters of the 
state (including wetlands), and MDNR authorization is not required. 

In a letter dated March 25, 2004, the USACE indicated it had previously reviewed the proposed 
Elm Avenue Diversion project and that it fell under an existing General Permit expiring January 
31, 2005. The USACE issued another letter on December 22, 2004 stating that the project will 
remain authorized by this General Permit 04-01253-TJF until December 22, 2006 (see Appendix 
B). Under this General Permit, the wetland impacts associated with the proposed project are 
considered to be minor and do not require specific mitigation measures. If the project is not 
constructed before December 22, 2006, the USACE will need to be contacted again to reissue or 
extend the permit.

Alternative 1  No Action 
Under this alternative, wetlands would continue to be subject to frequent flooding, causing 
potential sedimentation and contamination from sewer backups. This would cause temporary 
impacts to water quality, wildlife and plants during flood events, and could cause long-term 
degradation of the wetland system. 

Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Excavation and grading during construction of Alternative 2 would impact approximately 200 
square feet (SF) of Wetland 1 and approximately 200 SF of Wetland 2. This would occur along 
the proposed utility corridor. Existing vegetation would also be stripped while excavation and 
grading for pipe installation occurs. These impacts would be temporary and would last only for 
the duration of project construction.

As this is not a permanent impact, it does not carry 2:1 replacement requirements under the 
WCA or MDNR. To mitigate the temporary impacts, the disturbed wetland areas would be 
returned to their original elevations and would be replanted with native vegetation.
The inlet and outlets to be installed would provide these wetlands with a more consistent 
hydrologic regime, as compared to current conditions. The amount of water flowing through 
these areas would increase, since the watershed would be extended to include that of County 
Line Pond. The amount of water flowing through these areas would increase, since the watershed 
would be extended to include that of County Line Pond through the storm water improvements. 
As a result, it is likely that the wetland and potential wetland would expand in size and hold 
surface water for longer periods of time, in accordance with the design and elevation of the outlet 
structures. The quality of water entering the wetlands is expected to be similar to current 
conditions. The immediate watershed is developed with residential housing, as is the larger 
watershed of the proposed project.

Construction activities would require a permit from the LGU, which is the City of Delano. It is 
anticipated that the proposed project would meet the WCA criteria for Utilities Exemption (MN 
Rule 8420.0122). The wetlands are covered under existing USACE General Permit 04-01253-
TJF.

Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet
Alternative 3 would cause the same temporary wetland impacts as described under Alternative 2.  
As this is not a permanent impact, it does not carry 2:1 replacement requirements under the 
WCA or DNR. To mitigate the temporary impacts, the disturbed wetland areas would be 
returned to their original elevations and would be replanted with similar vegetation.

3.2.3 Threatened and Endangered Species
The Endangered Species Act (ESA) of 1973 requires Federal agencies to determine the effects of 
their actions on threatened and endangered species of fish, wildlife, and plants and on their 
habitats, and to take steps to conserve and protect these species.

The MDNR was contacted in February 2003 for information regarding known occurrences of 
threatened, endangered, or otherwise significant plant and animal species, natural plant 
communities, and other natural features.  In a letter dated November 10, 2003 (Appendix B), the 
MDNR concluded that there are four known occurrences of rare species or natural communities 
within an approximate one-mile radius of the project site. However, based on the nature and 
location of the proposed project, the DNR has determined that no known occurrences of rare 
features would likely be affected. The DNR confirmed that this determination was still 
acceptable in e-mail correspondence dated September 28, 2004 (Appendix B).

The United States Fish and Wildlife Service (USFWS) was sent a letter requesting review of the 
project for Federal threatened or endangered species. In e-mail correspondence dated January 6, 
2005, the USFWS documented that the federally-threatened bald eagle (Halieaeetus leucocephalus) is known to nest in Wright County, typically in floodplain forest environments. 
However, no bald eagles are known to nest within the project area. Therefore, the USFWS does 
not believe the project will have any adverse impacts on the bald eagle or any other Federal 
threatened or endangered species (Appendix B).

No impacts to threatened and endangered species are anticipated under any of the alternatives.

3.3 HAZARDOUS MATERIALS

The Resource Conservation and Recovery Act (RCRA) defines hazardous wastes as a solid 
waste, or combinations of solid wastes, which because of its quantity, concentration, or physical, 
chemical, or infectious characteristics may (1) cause, or significantly contribute to, an increase in 
mortality or an increase in serious irreversible or incapacitating reversible illness or (2) pose a 
substantial present or potential hazard to human health or the environment when improperly 
treated, stored, transported or disposed of or otherwise managed. While the definition refers to 
solids, it has also been interpreted to include semisolids, liquids, and contained gases (Wentz, 
1989).

Hazardous materials and wastes are regulated in Minnesota through a combination of federally 
mandated laws and State laws developed by the MPCA. Minnesota State Hazardous Waste Rules 
are contained in Chapter 7045 of the Minnesota Rules. Federal regulations governing hazardous 
wastes include RCRA; the Comprehensive Environmental Response, Compensation, and 
Liability Act (CERCLA); the Solid Waste Act (SWA); and the Toxic Substance Control Act 
(TSCA).

To determine the presence and approximate location of known hazardous materials in the 
vicinity of the proposed project, a database search was conducted by FirstSearch Technology 
Corporation (FirstSearch, 2005). The database search queried multiple Federal, State, and local 
hazardous materials and underground storage tank (UST) databases to identify sites of potential 
concern. Identified USTs were also cross-checked in the MPCA Storage Tank Database (MPCA, 
2004). Information was also utilized from a Phase 1 Environmental Site Assessment prepared for 
a nearby site in July 2004 (Wenck Associates, 2004).

Four sites were identified within 0.5 mile of the proposed project site. The closest is a leaking 
underground storage tank (LUST) site that lies approximately 0.25 mile west from the eastern 
edge of the proposed project, and approximately 400 feet south of the western edge of the 
proposed project. This site has been closed, meaning the MPCA is no longer requiring any 
investigative and/or cleanup action at the site. The MPCA also reports that no off-site 
contamination was released from the site. The remaining three sites are all approximately 0.25 to 
0.5 mile southeast of the proposed project site. One is a LUST containing diesel fuel. This site 
remains open, and contaminated soils remain on the site. It is unknown if off-site contamination 
has occurred. The other two sites are registered UST sites containing fuel oil, with no reported 
violations.

Based on review of topographic maps, the eastern edge of the project site lies at an elevation of 
approximately 950 feet, and the western edge lies at approximately 940 feet. Area elevations 
indicate that surface and groundwater drainage occurs to the northwest, toward the South Fork of 
the Crow River, and away from the proposed project site. This is also consistent with drainage 
described in the Citys Stormwater Management Plan (Bonestroo, 1997). All identified sites lie 
at lower elevations than the proposed project, in a presumed downgradient groundwater flow 
position. This information, combined with the distance of these sites from the project area, 
suggests risk of contamination from area sites is low.

No subsurface materials testing was conducted in the project area as part of this analysis. 
Conclusions are based on FirstSearch review, MPCA database search, and review of topographic 
maps and aerial photos.

Alternative 1  No Action
Under the No Action Alternative, no flood mitigation activities would be undertaken using 
FEMA funds. Hazardous wastes and materials that may be present in the project area would not 
be altered from their present condition.

Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Based upon the information reviewed, no impacts to hazardous materials or wastes are 
anticipated under Alternative 2. 

Although subsurface hazardous materials are not anticipated to be present in the project area, 
excavation activities could expose or otherwise affect subsurface hazardous wastes or materials. 
Any hazardous materials discovered, generated, or used during implementation of the proposed 
project would be disposed of and handled by the City in accordance with applicable local, State, 
and Federal regulations.

Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet
The second diversion associated with Alternative 3 would come within less than 50 feet of the 
closed LUST site. Although the site has been closed by the MPCA, contamination may remain in 
the soils on-site. There is a possibility that fuel oil could be encountered during excavation for 
the proposed piping.

Any hazardous materials discovered, generated, or used during implementation of the proposed 
project would be disposed of and handled by the City in accordance with applicable local, State, 
and Federal regulations. This would include excavation of any contaminated soils, and 
identification of proper management and disposal alternatives.

3.4 SOCIOECONOMICS

3.4.1 Zoning and Land Use
Wright County, Minnesota, was officially created in 1855. It is located in the east-central part of 
the State, and is one of seven counties in the Twin Cities Metropolitan Area. The size of the 
County is approximately 716 square miles (Wright County, 2003), containing 17 cities and 18 
townships. It is bordered by Sherburne and Stearns Counties to the north, Meeker County to the 
west, Carver and McLeod Counties to the south, and Hennepin County to the east. Due to Wright 
Countys proximity to the Twin Cities, it is considered one of the fastest growing counties in the 
State. The population of Wright County has increased 31 percent since 1990, to an estimated 
89,986 people.

The proposed project is located within the limits of the City of Delano, in the southeast corner of 
Wright County. The current population of the City is 3,847. It has experienced steady population 
growth, most recently experiencing a 38 percent growth in population between 1990 and 2000 
(U.S. Census Bureau, 2000).  It is anticipated that this trend will continue, with an estimated 
growth of 103 people per year through the year 2015 (Bonestroo, 1997). 
Land uses in the project area include a number of residential structures built in the 1970s. Delano 
High School borders the project site to the north. Delano Evangelical Free Church is also located 
adjacent to the proposed utility corridor at 730 Elm Avenue. The area is zoned residential with 
some institutional/public zoning.

Alternative 1  No Action
Under the No Action Alternative, there would be no land use and zoning changes. In a storm 
event, area residents would likely be affected by basement flooding and sanitary sewer backups. 
The frequent flooding and potential for property damage would also probably result in lower 
property values in the area over time.

Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Improvements under Alternative 2 are consistent with current land use and zoning in the project 
area. With the proposed improvements, the area would be better suited for continued growth.
Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet
Improvements under Alternative 2 are consistent with current land use and zoning in the project 
area. With the proposed improvements, the area would be better suited for continued growth.

3.4.2 Visual Resources
Visual resources refer to the landscape character (what is seen), visual sensitivity (human 
preferences and values regarding what is seen), scenic integrity (degree of intactness and 
wholeness in landscape character), and landscape visibility (relative distance of seen areas) of a 
geographically defined viewshed.

The general character of the project area is a residential neighborhood, bordered by public uses, 
namely Delano High School, to the northwest. The project sight is relatively flat to gently 
sloping. Views from a nearby residential home or from Elm Avenue would typically consist of 
other homes or limited open space areas, with some homes having a view of County Line Pond. 
Vegetation is typical of a residential neighborhood, consisting of mostly turf grass and some 
private landscaping, along with various deciduous trees. A relatively large, intact woodland is 
located around and to the north of Wetland 1. Wetlands in the northwest part of the project area 
are in open space areas that consist of grasses and typical wetland plants. 

Alternative 1  No Action
Under the No Action Alternative, no activities would be undertaken and visual resources would 
not be affected. In a storm event, County Line Pond would overflow and flood the surrounding 
open space area.

Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Under Alternative 2, larger piping would be installed underground and would not be visible to 
the public. During construction, overturned earth would be visible in the installation areas, as 
well as construction fencing and equipment. Post-construction, the disrupted soil would be 
seeded with grass to match the existing turf or vegetation.  These would be temporary impacts. 
The planting of native and non-invasive species to mitigation impacts to vegetation would be a 
visual enhancement to the area.

Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet
Heavy equipment would be seen in the project area during construction, and staging areas would 
be visible from some homes as described under Alternative 2. However, these would be 
temporary impacts. The planting of native and non-invasive species to mitigation impacts to 
vegetation would be a visual enhancement to the area.

3.4.3 Noise
Sound is most commonly measured in decibels (dB) on the A-weighted scale, which is the scale 
most similar to the range of sounds that the human ear can hear. The Day/Night Average Sound 
Level (DNL) is an average measure of sound. The DNL takes into account the volume of each 
sound incident, the number of times each incident occurs, and the time of day each incident 
occurs (nighttime sound is weighted more heavily because it is assumed to be more annoying to 
the community). The DNL descriptor is accepted by Federal agencies as a standard for 
estimating sound impacts and establishing guidelines for compatible land uses.

Noise, defined herein as unwanted or unwelcome sound, is regulated by the Federal Noise 
Control Act (NCA) of 1972. Although the NCA gives the EPA authority to prepare guidelines 
for acceptable ambient noise levels, it only requires those Federal agencies that operate noise-
producing facilities or equipment to implement noise standards. EPA guidelines (and those of 
many Federal agencies) state that outdoor sound levels in excess of 55 dB DNL are normally 
unacceptable for noise-sensitive land uses such as residences, schools, and hospitals. Noise 
sensitive receivers in the vicinity of the project consist of residences, a school, and a church.
City ordinance dictates that construction can only occur between 7:00 AM and 7:00 PM Monday 
through Saturday.

Alternative 1  No Action
Under the No Action Alternative, proposed activities would not occur and noise levels would be 
anticipated to remain at current levels.

Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Noise associated with Alternative 2 would be limited to construction noise emitted by 
mechanical equipment, including a backhoe, trucks, and a skid steer. Noise typically associated 
with this type of construction equipment can measure as much as 80 dB within 50 feet of the 
source, attenuating at a rate of 6 dB per doubling of distance away from the source.
Noise sensitive receivers in the project area include residences, Delano High School, and a 
church. The closest residence is roughly 30 feet away from the proposed project, and the church 
is approximately 200 feet away.  Construction at the high school would be approximately 400 
feet away from the classroom buildings, and across a parking lot. Pipe installation would also 
occur approximately 70 feet away from the tennis courts.

Construction activities may minimally disturb these receivers. However, noise would not be 
continuous, and would be restricted to daylight hours. Therefore, the disturbance would be 
temporary and would not be concentrated in one area for the entire five-month construction 
period, and all of the sensitive noise receivers would not be affected at the same time. 
Construction would also take place in the summer months to avoid disturbing high school 
classes, as no summer classes take place at the high school (Farbo, personal communication). 
Construction would not take place on Sunday and would therefore not interfere with church 
services.

Area residents may also experience daily noise from trucks hauling to and from staging areas and 
the project site. However, this impact would be temporary and would be spaced out over the 
daily hours of construction.

To mitigate for any potential noise impacts, the City would inform residents of the time and 
duration of project activities. All activities would conform to the set hours of 7:00 AM to 7:00 
PM as dictated by city ordinance. Construction equipment would be kept in good repair to ensure 
that proper noise muffling is maintained. Appropriate protective gear would be required to 
ensure the hearing protection of project workers.

Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet 
Noise associated with Alternative 3 would be limited to construction noise emitted by 
construction equipment as described above under Alternative 2, as both alternatives follow most 
of the same alignment and are in the same study area.
 
Noise sensitive receivers in the project area are the same as those described above under 
Alternative 2. Mitigation for any noise impacts would occur as discussed under Alternative 2.

3.4.4 Public Services and Utilities
There are currently 18- to 24-inch storm sewer pipes running along portions of the proposed 
project route. These pipes would be replaced with 24- to 36-inch pipe under the proposed action. 
There are also sanitary sewer lines in the project area. In the past, sanitary sewer backup has also 
occurred in conjunction with flooding of County Line Pond. Flooded basements contribute to 
sanitary sewer problems by causing inflow and infiltration of stormwater into the sanitary 
system. 

There are no other utilities (electric, gas) within the proposed project route.

Alternative 1  No Action
Under the No Action Alternative, periodic flooding would still occur, potentially affecting 
residential utilities and access to Elm Avenue. Nearby residents would still experience flooding 
and septic system backup.

Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Under Alternative 2, the existing storm sewer would be replaced with larger diameter piping. 
This would help to decrease the overburden on existing drainage systems and the subsequent 
infiltration of the sanitary sewer, which currently results in flooding and septic system backup 
during significant storm events. No other utilities would be affected by this alternative.
Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet 
Alternative 3 would provide the same benefits to the storm sewer system and sanitary sewer as 
described under Alternative 2. No other utilities would be affected by this alternative.

3.4.5	Traffic and Circulation
The proposed project involves upsizing storm sewer piping beneath part of Elm Avenue, which 
is a two-lane residential street maintained by the City. There is also a designated bike lane that 
runs along the north side of Elm Avenue in the project area. The existing storm sewer piping lies 
on the south side of Elm Avenue, and would be supplemented with a diversion that cuts across 
Elm Avenue in the vicinity of Oak Ridge Drive. This area would be open-cut to accommodate 
larger piping and new piping during the proposed project.

Alternative 1  No Action
Under the No Action Alternative, the existing storm sewer beneath Elm Avenue would not be 
disturbed, and no diversions would be constructed. No impacts to Elm Avenue or the bike lane 
would occur.

Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Under Alternative 2, construction would occur on Elm Avenue for one day during total project 
construction. One lane would be closed at a time to ensure that the street can remain open to 
traffic for the entire day. A flagman would be on-site to manage traffic. When the westbound 
lane is closed (north side of Elm Avenue), the bike lane would also be closed. Cyclists would be 
able to use the eastbound traffic lane under the guidance of the flagman at this time. Access 
would be maintained to the school, church, and all residences during construction.
Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet 
Under Alternative 3, construction would occur on Elm Avenue for one day during total project 
construction. One lane would be closed at a time to ensure that the street can remain open to 
traffic for the entire day. A flagman would be on-site to manage traffic. When the westbound 
lane is closed (north side of Elm Avenue), the bike lane would also be closed. Cyclists would be 
able to use the eastbound traffic lane under the guidance of the flagman at this time. Access 
would be maintained to the school, church, and all residences during construction.

3.4.6	Environmental Justice (EO 12898)
EO 12898 requires Federal agencies to make environmental justice part of their mission. 
Agencies are required to identify and correct programs, policies, and activities that have 
disproportionately high and adverse human health or environmental effects on minority and low-
income populations. EO 12898 also tasks Federal agencies with ensuring that public notifications 
regarding environmental issues are concise, understandable, and readily accessible. 
Socioeconomic and demographic data were studied to determine if a disproportionate number 
(greater than 50 percent) of minority or low-income people have the potential to be adversely 
affected by the alternatives.

Table 1 summarizes the demographic information for Wright County and the City of Delano, in 
comparison to averages for the State of Minnesota.

Table 1. Demographic Information is not available online in txt format. Please 
view the HTML file at: http://www.fema.gov/ehp/docs.shtm

Based on review of the above information, a disproportionate effect on minority or low-income 
populations would not occur with any of the alternatives. The City is consistent with Wright 
County and well below State averages for minorities and persons below poverty level. 
Additionally, Alternatives 2 and 3 would reduce potential future flooding of basements and 
backup of the sanitary sewer system, and would benefit all people residing within the project 
area. Therefore, the project is in compliance with EO 12898.

3.4.7	Safety and Security
Safety and security issues considered in this analysis include the health and safety issues of the 
area residents and the public at-large, and the protection of personnel involved in activities 
related to the implementation of the Proposed Action.

EO 13045, Protection of Children, requires federal agencies to make it a high priority to identify 
and assess environmental health and safety risks that may disproportionately affect children.  

Alternative 1  No Action
Under the No Action Alternative, the potential for future flooding of basements and backup of 
sanitary storm sewers would remain. Residents would also be susceptible to injury or negative 
health impacts due to unsanitary conditions following flooding, including the significant and 
widespread health and safety risk to residents who experience raw sewage backup into their 
homes. 

Since the No Action Alternative does not involve the employment of personnel to perform the 
project activities, there would be no potential risks to the personal safety of project workers.
Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Under Alternative 2, storm sewer improvement activities could present safety risks to individuals 
performing the activities. To minimize risks to safety and human health, all project activities 
would be performed using qualified personnel trained in the proper use of the appropriate 
equipment, including safety precautions. In addition, all activities would be conducted in 
accordance with Occupational Safety and Health Administration (OSHA) regulations.

Implementation of Alternative 2 would increase the capacity of the storm sewer system. This 
would reduce the risk of injury and negative health impacts to residents as a result of flooding 
and storm sewer backup.

Persons of all ages reside in the project area neighborhood, and youth ages 14 through 19 attend 
nearby Delano High School. Additional protection will be ensured at the project site by the used 
of cautionary signage and protective fencing. Children would not be disproportionately affected 
by the proposed project; therefore the project is in compliance with EO 13045.

Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet
Under the Alternative 3, storm sewer improvement activities could present safety risks to 
individuals performing the activities. Actions to minimize risks to safety and human health 
would be completed as described under Alternative 2, as both alternatives follow similar 
alignment and would require similar construction activities.

Implementation of Alternative 3 would increase the capacity of the storm sewer system. This 
would reduce the risk of injury and negative health impacts to residents as a result of flooding 
and storm sewer backup.

Persons of all ages reside in the project area neighborhood, and youth ages 14 through 19 attend 
nearby Delano High School. Children would not be disproportionately affected by the proposed 
project; therefore the project is in compliance with EO 13045.

3.5 CULTURAL RESOURCES
In addition to review under NEPA, consideration of impacts to cultural resources is mandated 
under Section 106 of the National Historic Preservation Act, as amended, and implemented by 
36 CFR Part 800. Requirements include identification of significant historic properties that may 
be affected by the proposed project. Historic properties are defined as archaeological sites, 
standing structures, or other historic resources listed in or eligible for listing in the National 
Register of Historic Places (NRHP) (36 CFR 60.4).

As defined in 36 CFR Part 800.16(d), the Area of Potential Effect (APE) is the geographic area 
or areas within which an undertaking may directly or indirectly cause changes in the character or 
use of historic properties, if any such properties exist.

In addition to identifying historic properties that may exist in the APE of the Proposed Action, 
FEMA must also determine, in consultation with the appropriate State Historic Preservation 
Office (SHPO), what effect, if any, the action would have on historic properties. Moreover, if the 
project would have an adverse impact on these properties, FEMA must consult with the SHPO 
on ways to avoid, minimize, or mitigate the adverse effect.

The Minnesota Department of Public Safety/Homeland Security and Emergency Management 
initiated consultation with the SHPO in October 2003. The SHPO responded in a letter dated 
December 2, 2003 that no properties eligible for or listed in the NRHP are within the projects 
area of effect. In an e-mail dated October 1, 2004, the SHPO stated that its review findings from 
2003 remain the same (See Appendix B).

Alternative 1  No Action
Under the No Action Alternative, there would be no effects to cultural resources because 
proposed improvements would not occur.

Alternative 2  Elm Avenue Diversion and Increase Size of Pond Outlet (Proposed Action)
Based on research and the archaeological survey, it is not anticipated that any NRHP-eligible or 
listed properties exist within the proposed project area; however, if artifacts or human remains 
are encountered during construction, work in the vicinity would be halted, and FEMA, the Office 
of the State Archaeologist (OSA), and the SHPO would be immediately contacted.

Alternative 3  Two Diversions from Elm Avenue and Increase Size of Pond Outlet
As under Alternative 2, it is not anticipated that any NRHP-eligible or listed properties exist 
within the project area for Alternative 3; however, if artifacts or human remains are encountered 
during construction, work in the vicinity would be halted, and FEMA, the OSA, and the SHPO 
would be immediately contacted.

3.5.1 Tribal Coordination
Initial American Indian group contacts were suggested by the Minnesota SHPO (see list in 
Section 7). Letters were sent to the list of potential consulting and interested parties on October 
29, 2004. 

Follow-up consultation was initiated on April 8, 2005. A response was received from the 
Shakopee Mdewakanton Community, which expressed an interest in any areas of potential 
historical significance that may be disturbed (see Appendix B). Consultation with the SHPO was 
addressed as discussed above. The American Indian community will continue to be notified of 
project progress, and will be involved in review of this EA


Table 2. Impact Summary Matrix 
Table 2 is extensive and i not available online in txt format. Please 
view the HTML file at: http://www.fema.gov/ehp/docs.shtm

Section 4 CUMULATIVE IMPACTS

Cumulative impacts are those effects on the environment that result from the incremental effect 
of the action when added to past, present, and reasonably foreseeable future actions regardless of 
what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative 
effects can result from individually minor, but collectively significant, actions taking place over 
a period of time.

Four HMGP projects are currently proposed within the City of Delano. The Elm Avenue 
Diversion project is one of these four projects. The other three include the East Side Lift Station 
project, the West Side Lift Station, and Alley Resurfacing (Figure 5). All of these projects are 
designed to control excessive flooding that has plagued the City of Delano in recent years. On 
many occasions in 2001 and 2002, the City was forced to conduct emergency pumping and 
sandbagging activities to attempt to protect local homes and businesses.

Cumulatively, a basic hydraulic analysis of total stormwater discharge from the four projects 
compared to total watershed size indicates these projects will not have substantial negative 
impacts on the South Fork of the Crow River system or the floodplain system as a whole 
(Bonestroo, 1997). The Elm Avenue Diversion would direct water to the area south of the high 
school, which is part of the same system of ditches and wetlands that would eventually run 
through the East Side Lift Station and to the South Fork of the Crow River. The northeast portion 
of the Alley Resurfacing Project would also direct water through wetlands to the East Side Lift 
Station, with the remainder of the area draining through the existing stormwater piping to the 
river. The West Side Lift Station would serve the west part of the City, collecting stormwater for 
discharge to the river. Collectively, during a 100-year flood event the projects would deliver 
approximately 120 cfs to the South Fork of the Crow River. This is derived from the 40 cfs 
pumping capacity at East Side Lift Station (which would collect water from the Elm Avenue 
Diversion and the Alley Resurfacing Project) and the 80 cfs of pumping capacity at the West 
Side Lift Station. Using the June 2002 flood example of 13.5 feet, the South Fork of the Crow 
River is flowing at 6,489 cfs (National Weather Service, 2005). The impact of the addition of 
120 cfs is negligible at 1.8 percent. This slight increase would not increase the elevation of the 
100-year floodplain or impact downstream areas (Krogstad, personal communication).

With these projects implemented, the City of Delano would be better able to manage its 
stormwater and floodwater during and after storm events. This allows for quicker emergency 
response, and also contributes positively to the overall quality of life for Delano residents. Better 
water management would reduce risk of property damage from flooding, and protect residents 
from health and safety risks associated with excess water and sewer backups. The City would be 
able to expend money on other necessary municipal improvements and programs, instead of 
funding extensive emergency pumping activities.  

It is not anticipated that floodplain development would be promoted as a result of implementing 
the proposed projects. The City of Delano has an existing Floodplain District Ordinance that 
prohibits development within the floodway of the South Fork of the Crow River within the City. 
In addition, the City has actively pursued and successfully obtained Flood Damage Reduction 
(FDR) grant funding from the WDNR to purchase and remove repetitive loss properties within 
the 100-year floodplain. The former Bock property, at the site of the proposed West Side Lift 
Station, was purchased under this grant. The City continues to identify and pursue funding for 
removal of additional properties. Currently, FDR funding has been received for removal of a 
residence in the south part of the city, and two other commercial properties along the east bank 
of the river in the downtown area are also slated for acquisition and demolition (Fick, personal 
communication).

Individually, each of the projects would have long-term positive impacts on the natural 
environment. Any combination of these projects would magnify these benefits citywide. 
Managing stormwater and handling floodwater more efficiently would create a more consistent 
hydrologic regime for wetlands, which supports stable habitat and plant and animal life, as well 
as overall water quality. A more controlled system would also reduce erosion and sedimentation 
impacts that result from emergency pumping, standing basins of floodwater, and overtopping of 
roads and basins.

Section 5 PUBLIC PARTICIPATION

The Delano Stormwater Task Force (Task Force) was appointed by the Delano City Council on 
November 12, 2002. This was a nine-member committee appointed to identify priorities for 
flood mitigation projects within the City. Members included City residents as well as two 
professional engineers. Task Force meetings were held on the following dates:
-November 21, 2002
-December 6, 2002
-December 12, 2002
-December 19, 2002
-January 6, 2003
-January 9, 2003
-January 30, 2003
-February 5, 2003
-February 19, 2003
-March 13, 2003  joint meeting with City Council

All City Council meetings are open to the public and are also locally televised. Minutes from 
meetings are also available on the City of Delano website. A specific public hearing discussing 
sump pump operations and the Citys stormwater drainage ordinance was held February 4, 2003. 
The public notice from this meeting is included on the following page.

Public notice advertising the availability of the draft EA for public review has been drafted and 
included in Appendix E. This notice has been provided to The Delano Eagle newspaper and will 
also be available for review online at the FEMA website: http://www.fema.gov/ehp/docs.shtm. 
The public will be provided 30 days for comment on the Proposed Action. The FEMA Region V 
office will collect and compile comments submitted by the public.

At the conclusion of the public review period, a summary of any comments received will be 
provided in this section and copies of the comments will be included in Appendix E.


Section 6 Mitigation Measures and Permits

The following table provides a summary of the anticipated permitting and mitigation 
requirements for the proposed project alternatives.

Table 3. Permits and Mitigation by Alternative
Alternatives
Permit/Mitigation Requirements
Alternative 1  No 
Action
No permits or mitigation measures are required.

Alternative 2  Elm 
Avenue Diversion 
and Increase Size of 
Pond Outlet
and
Alternative 3  Two 

-Erosion would be minimized through the use of BMPs, 
including protecting erodible surfaces (through 
mechanisms such as silt fences) and not working during 
precipitation events.
-An NPDES permit would be obtained for proposed 
project grading.
-Exposed soils would be seeded in accordance with the 
NPDES permit. Native/non-invasive species would be 
used whenever feasible.
-Compacted soils would be loosened by disking or raking
-Project would be in compliance with EO 79-19 and the 
MNRRA/MRCA.
-Vehicle engines would be kept in good repair and turned 
off while not in use to prevent air emissions.
-Project access roads would be watered when conditions 
are dusty.
-Any hazardous materials discovered, generated, or used 
during implementation of the proposed project would be 
disposed of and handled by the City in accordance with 
applicable local, State, and Federal regulations.
-Vegetation would be replanted with native species or 
species comparable to existing vegetation.
-A WCA Exemption for wetlands will be applied for 
before construction begins.
-Wetland impact covered under existing USACE General 
Permit 04-01253-TJF.
-To mitigate for any potential noise impacts, the City 
would inform residents of the time and duration of 
project activities to help mitigate noise impacts. 
-All activities would conform to the hours of construction 
set by the City (7:00 AM through 7:00 PM Monday 
through Saturday).
-Appropriate gear would be required to protect the 
hearing of project workers.
-Appropriate signage would direct drivers to detours, and 
would inform them of work zones and equipment 
transport routes.
-All project activities would be performed using qualified 
personnel trained in the proper use of the appropriate 
equipment, including safety precautions.
-All activities would be conducted in accordance with 
OSHA regulations.
-If artifacts or human remains are encountered during 
construction, work in the vicinity would be halted, and 
FEMA, the OSA, and the SHPO would be immediately 
contacted.
-Flagging and fencing would be used to limit 
construction staging and parking areas. 


7.1 CONSULTATIONS

7.1.1 Agency Coordination 
The Minnesota Office of Homeland Security and Emergency Management sent initial 
consultation letters to the following agencies in October 2003: 
-Minnesota Department of Natural Resources, Division of Waters
-State Historic Preservation Office
-U.S. Army Corps of Engineers

These agencies were contacted again by URS in September/October 2004 to ensure that findings 
relayed in 2003 were still applicable to the project. Agencies were sent a summary of the project 
and an update on the NEPA process.
 
In addition, MDNR consultation for rare, threatened, and endangered species was initiated by the 
Minnesota Office of Homeland Security and Emergency Management in February 2003. 
Consultation with the USFWS was initiated by URS in October 2004, and the MDNR Natural 
Heritage Program (NHP) was also contacted to ensure that the original findings were still 
applicable to the project.  The findings of the USFWS and the MDNR NHP are incorporated into 
the EA. These responses are included in Appendix B. 

Additional consultations included:
-Federal Emergency Management Agency
-Minnesota Department of Public Safety - Homeland Security and Emergency Management
-City of Delano

7.1.2 Distribution
The following will receive a copy of the Draft EA:

Federal Agencies
U.S. Army Corps of Engineers
U.S. Department of the Interior, U.S. Fish and Wildlife Service

Tribes
Lower Sioux Community
Prairie Island Indian Community
Shakopee Mdewakanton Sioux Community
Upper Sioux Community

State, County, and Local Agencies
Minnesota Department of Emergency Management
Minnesota Department of Natural Resources
State Historic Preservation Office
Office of the State Archaeologist
Minnesota Indian Affairs Council
City of Delano

7.2 REFERENCES
Bonestroo Rosene Anderlik & Associates. 2002. June 2002 Flood Analysis, Delano, Minnesota. 
File No. 280-02-124. 

Bonestroo Rosene Anderlik & Associates. 1997. Stormwater Management Plan, Delano, 
Minnesota. File No. 28066. 

City of Delano. 2002. City of Delano Web Page, Home Page. http://www.delano.mn.us 
Accessed August 11, 2004.

Delano, Minnesota. 2003. Delano Citisite: For the Community, From the Community. 
http://delano.citisite.com/ Accessed August 11, 2004.

Delano School District. 2004. http://www.delano.k12.mn.us/sitepages/pid45.php Accessed 
October 29, 2004.

Environmental Protection Agency (EPA). 2003. Air Quality. Accessed August 20, 2004 from 
http://www.epa.gov/air/oaqps/greenbk/mapnpoll.html.

League of Minnesota Cities. 2004. Census 2000 Update: Expanded Minnesota Profiles. 
http://www.lmnc.org/census/census.cfm Accessed August 20, 2004

Minnesota Pollution Control Agency (MPCA). 2004. Minnesota 305(b) Report to Congress of 
the United States, Assessments of Stream Conditions in Minnesotas Major River Basins. 
Retrieved September 14, 2004 from 
http://www.pca.state.mn.us/water/basins/305briver.html.

MPCA. 2003. Storage Tank Systems. Accessed September 23, 2004 from 
http://www.pca.state.mn.us/cleanup/tanks.html.

National Park Service (NPS). 2003. Wild and Scenic Rivers by State, 
http://www.nps.gov/rivers/wildriverslist.html#mn. Accessed November 28, 2003.

U.S. Census Bureau. 2000. Accessed August 20, 2004 from http://www.census.org

U.S. Department of Agriculture (USDA). 1968. Soil Survey of Wright County, Minnesota. United 
States Department of Agriculture, Soil Conservation Service in cooperation with the 
Minnesota Agricultural Experiment Station. Washington, D.C.

Wenck Associates, Inc. 2004. Phase I Environmental Site Assessment, Bock Property, 102 
Babcock Boulevard West, Delano, MN. Prepared for City of Delano.
Wentz, C. 1989. Hazardous Waste Management. McGraw-Hill Chemical Engineering Series: 
New York.

Wright County. 2003. Wright County Web Page, Home Page, http://www.co.wright.mn.us. 
Accessed August 16, 2004.

Personal Communication

Anfinson, Scott. SHPO. Personal communication with Evelyn Tidlow, URS Vice President, 
October 18.

Fairchild, Laurie, U.S. Fish and Wildlife Service. 2004. Personal communication with Jessica 
Overmohle, URS Environmental Planner, September 28.

*Farbo, Susan, Delano High School. Personal communication with Jessica Overmohle, URS 
Environmental Planner, November 10.

Fell, Tim, USACE. Personal communication with Lydia Nelson, URS Professional Wetland 
Scientist, October 15.

*Fick, Ed, MDNR, Hydrologist. Personal communication with Jessica Overmohle, URS 
Environmental Planner, July 22, 2005.

Fowler, Patricia, DNR, Area Hydrologist. Personal communication with Jessica Overmohle, 
URS Environmental Planner, September 28.

*Krogstad, Brad, URS Engineer. Personal Communication with Jessica Overmohle, URS 
Environmental Planner, July 25, 2005.

Torve, Kent, Wenck Associates, Inc., City Engineer for Delano. 2004. Personal communication 
with Jessica Overmohle, URS Environmental Planner, ongoing throughout project 
process.

Torve, Kent, Wenck Associates, Inc., City Engineer for Delano. 2004. Personal communication 
with Lydia Nelson, URS Professional Wetland Scientist, October 6.

*Referenced in text; for Record of Conversation please view the HTML file at: http://www.fema.gov/ehp/docs.shtm



Section 8 List of Preparers
Lydia Nelson, Professional Wetland Scientist, URS-Minneapolis (MSP)  Peer Reviewer/Field 
Assessment/Floodplain Review. Conducted field research for Water Resources and Water 
Quality, Floodplain Management, Terrestrial and Aquatic Environment, Wetlands. 

Jessica Overmohle, Environmental Planner, URS-MSP  Technical Researcher and Task 
Coordinator. Author of sections on Purpose and Need, Alternatives, Geology, Seismicity, and 
Soils, Air Quality, Hazardous Materials, Threatened and Endangered Species, Zoning and Land 
Use, Visual Resources, Noise, Public Services and Utilities, Traffic and Circulation, 
Environmental Justice, Safety and Security, Cumulative Impacts.

Evelyn Tidlow, Vice President, URS-MSP  Peer Reviewer.

Amy Siegel, Document Control Supervisor, URS-Gaithersburg (GTB)  Document Quality 
Control.

Rhonda Taylor, PE, URS-GTB  Engineering/Floodplain Review.

Stephen Carruth, FEMA National Environmental Coordinator, URS-GTB  Independent 
Technical Reviewer.

Jeanne Witzig, URS-MSP  Project Manager.



Figures

Figure 1 - Regional Location - shows location of the City of Delano in relation to the state of Minnesota.

Figure 2 - Project Location - shows location of the project within the east/northeast part of the City of Delano.

Figure 3 - Proposed Alternatives - shows location of proposed pipes for Alternatives 2 and 3, as well as location
of wetlands and County Line Pond. Aerial background also shows Delano High School and other surrounding land uses.

Figure 4 - FEMA Floodplain - shows location of FEMA 100-year floodplain in City of Delano. Project lies east of the 
floodplain boundary.

Figure 5 - Proposed HMGP Project Locations - shows locations of 4 flood mitigation projects proposed within the City, 
including Elm Avenue Diversion, East Side Lift Station, West Side Lift Station, and Alley Resurfacing.

Appendix A
Project Area Photographs

 
View of County Line Pond, facing south/southwest toward Elm Avenue.
 
View from low area between County Line Pond and Elm Avenue, facing north toward Elm Avenue.
 
Looking east along the north side of Elm Avenue.
 
Typical vegetation through which pipe will be installed north of Elm Avenue.
 
Wetland 1, north of Elm Avenue

Appendix B
Agency Correspondence

Results of agency correspondence are summarized in the main body of the document. For information on the availability of 
specific agency letters which were not posted due to formatting issues, please use contact instructions given in the public
notice.




Appendix C
Best Management Practices

For information on the availability of Appendix C which is not included due to size formatting 
issues, please use contact instructions given in the Public Notice.

Appendix D
EO 11988 and EO 11990 Eight-Step Planning Proces

Step 1: Determine whether the Proposed 
Action is located in a wetland and/or the 100-
year floodplain, or whether it has the potential 
to affect or be affected by a floodplain or 
wetland.

Project Analysis: The City of Delano is a 
participant in good standing with the NFIP. 
According to FEMA mapping, the proposed 
project is not located in the 100-year floodplain of 
the South Fork of the Crow River. 

According to NWI maps and a site visit conducted 
by URS on September 17, 2004, there are two 
wetlands in the project area.

Step 2: Notify public at earliest possible time 
of the intent to carry out an action in a 
floodplain or wetland, and involve the affected 
and interested public in the decision-making 
process.

Project Analysis: Status of the project has been 
discussed at numerous Delano City Council 
meetings to date. The project was also developed 
by a citizen task force which met nine times in 
2003, and whose findings were reported to the 
City Council. All City Council meetings are open 
to the public and are also locally televised. 
Minutes from all meetings are also available on 
the City of Delano website.

A notice will also be published by the Applicant 
in a newspaper of general circulation when the EA 
is made available for public review.

Step 3: Identify and evaluate practicable 
alternatives to locating the Proposed Action in 
a floodplain or wetland.

Project Analysis:  The City of Delano lies in an 
area that characteristically has a number of low-
lying and wetland areas. The Proposed Action 
includes the least amount of wetland impact that 
still allows for the project to proceed, and 
consequently will only incur temporary wetland 
impact and no long-term wetland impact. Other 
than the No Action Alternative, there are no 
practicable alternatives for improving the storm 
sewer system that would not involve impacts to 
wetlands.

The Proposed Action is not located within, and 
therefore would not directly impact, the 100-year 
floodplain. The Proposed Action would not 
increase the 100-year flood elevation of the South 
Fork of the Crow River.

The following alternatives were evaluated in the 
EA:
Alternative 1: No Action

Alternative 2: Proposed Action
Installation of 1,900 feet of 24- to 36-inch storm 
sewer piping from County Line Pond, across and 
within Elm Avenue, to an area southwest of 
Delano High School, while also increasing the 
size of the County Line Pond outlet.

Alternative 3
Installation of 1,900 feet of 24- to 36-inch storm 
sewer piping from County Line Pond, across and 
within Elm Avenue, to an area southwest of 
Delano High School, in addition to installation of 
a second 30-inch connection from the storm sewer 
on Elm Avenue to the newly proposed 36-inch 
pipe south of Delano High School. The size of the 
County Line Pond outlet would also be increased. 

Alternatives Considered but Eliminated
The enlargement of County Line Pond and 
replacement of storm sewer on Elm Avenue was 
also considered as an alternative to this project.  
However, this alternative was dismissed because 
it would require excavation and would 
significantly increase project costs. 

The City of Delano also considered installing 
even larger pipe on Elm Avenue. However, this 
alternative was dismissed because it would cause 
additional wetland impacts and large amounts of 
street repair on Elm Avenue. 

Step 4: Identify the full range of potential 
direct or indirect impacts associated with the 
occupancy or modification of floodplains and 
wetlands, and the potential direct and indirect 
support of floodplain and wetland development 
that could result from the Proposed Action.
Project Analysis: The project will result in only 
temporary impacts to both identified wetlands. No 
permanent excavation would take place, and 
vegetation would be restored after construction. 
The water entering the wetlands from the enlarged 
storm sewer pipe would be filtered by vegetation 
in County Line Pond before it reaches either 
wetland.

Step 5: Minimize the potential adverse impacts 
to work within floodplains and wetlands to be 
identified under Step 4, restore and preserve 
the natural and beneficial values served by 
wetlands.

Project Analysis: As wetland impacts are 
anticipated to be temporary, there will be no 
replacement requirements necessary.
The Applicant must follow all applicable local, 
State, and Federal laws, regulations, and 
requirements and obtain and comply with all 
required permits and approvals, prior to initiating 
work on this project. This will include a WCA 
exemption for wetlands and a USACE letter of 
Jurisdictional Determination. No staging of 
equipment or project activities shall begin until all 
permits are obtained. The Applicant must apply 
BMPs for soil erosion prevention and containment 
during staging of equipment and project activities. 
Should project activities be delayed for 1 year or 
more after the date of this EA, coordination and 
project review by the appropriate regulating 
agencies must be re-initiated.

There are no anticipated impacts to the 100-year 
floodplain or the 100-year flood elevation of the 
South Fork of the Crow River. Impacts of other 
project adjoining this storm water system will be 
reviewed as necessary to ensure that cumulative 
impacts to the floodplain are addressed.

Step 6: Re-evaluate the Proposed Action to 
determine: 1) if it is still practicable in light of 
its exposure to flood hazards; 2) the extent to 
which it will aggravate the hazards to others; 3) 
its potential to disrupt floodplain and wetland 
values.

Project Analysis: The Proposed Action remains 
practicable based on the storm sewer 
improvement objectives.

Step 7: If the agency decides to take an action 
in a floodplain or wetland, prepare and provide 
the public with a finding and explanation of 
any final decision that the floodplain or 
wetland is the only practicable alternative. The 
explanation should include any relevant factors 
considered in the decision-making process.
Project Analysis: A public notice will be 
submitted informing of FEMAs decision to 
proceed with the project. This notice will include 
rationale for wetland impacts; a description of all 
significant facts considered in making the 
determination; a list of the alternatives considered; 
a statement indicating whether the action 
conforms to State and local wetland protection 
standards; a statement indicating how the action 
affects the wetlands; and a statement of how 
mitigation will be achieved.

Step 8: Review the implementation and post-
implementation phases of the Proposed Action 
to ensure that the requirements of the EOs are 
fully implemented. Oversight responsibility 
shall be integrated into existing processes.
Project Analysis: This step is integrated into the 
NEPA process and FEMA project management 
and oversight functions.



Appendix E
Public Notice


Federal Emergency Management Agency
PUBLIC NOTICE
Notice of Availability for Draft Environmental Assessments
For Elm Avenue Diversion, East Side Lift Station and West Side Lift Station
Delano, Wright County, MN

Environmental Assessments for Elm Avenue Diversion, East Side Lift Station, and West Side 
Lift Station; City of Delano, Wright County, Minnesota. FEMA-MN-2003-MN.

Interested persons are hereby notified that the Federal Emergency Management Agency 
(FEMA)/Department of Homeland Security (DHS) is proposing to assist in the funding of storm 
sewer system improvements to mitigate and prepare for damage caused by flooding in the City 
of Delano. In accordance with the National Environmental Policy Act (NEPA) of 1969 and the 
implementing regulations of FEMA, Environmental Assessments (EAs) are being prepared to 
assess the potential impacts of each of the proposed actions on the human and natural 
environment. This also provides public notice to invite public comments on the proposed project 
in accordance with Executive Order 11988, Floodplain Management, and Executive Order 
11990, Protection of Wetlands. In addition, this notice and the draft EAs provide information to 
the public on potential impacts to historic and cultural resources from the proposed undertaking, 
as outlined in the National Historic Preservation Act of 1966.

The draft EAs are available for review between August 22, 2005 and September 20, 2005 at 
Delano Public Library, 140 Bridge Avenue East, and Delano City Hall, 234 2nd Street North, 
during normal hours of operation. A public meeting will be held to discuss these three proposed 
FEMA projects in Delano on September 6, 2005 from 6:00 PM to 7:00 PM at Delano City Hall.  
The draft EA is also available for review online at the FEMA website 
http://www.fema.gov/ehp/docs.shtm.

Written comments regarding this environmental action should be received no later than 5PM on 
September 20, 2005, by Jeanne Millin, Regional Environmental Officer, 536 South Clark, 6th 
Floor, Chicago IL 60605-1521, or at Jeanne.Millin@dhs.gov.

If no comments are received by the above deadline, the draft EA will be considered final and a 
Finding of No Significant Impact will be published by FEMA.

The public may request a copy of the final environmental documents from Jeanne Millin at the 
address listed above.