County Board Order For EIS on LWBC Proposal

 

 

PETITION FOR AN ENVIRONMENTAL ASSESSEMENT WORKSHEET

To determine the impact on Deer Lake by Living World Bible Camp.

 

 

DESCRIPTION OF THE PROPOSED PROJECT

 

The Living World Bible Camp (LWBC) proposes to create a Commercial Planned Unit Development (PUD) on a 270-acre parcel, which borders 3000 ft of lakeshore on Deer Lake, in Itasca County.  The preliminary proposal for the Commercial PUD consists of a three-level Lodge approximately 20,500 square feet to house a chapel, meeting space with fireplace, commercial kitchen, dining room, gift shop, game room, offices, nurses office and sickroom, production and storage room, four rest rooms, mezzanine level unknown, population capacity unknown; five three-level housing units at 4,544 square feet each and housing 29 occupants with living room, fireplace, kitchen, bedrooms each with full baths and two additional sinks, lower level apartments, mezzanine unknown; one two-level office building at 3600 sq ft; gymnasium-activity center at 7,000 sq ft; Campfire/ Amphitheater area approximately 2,500 sq ft; maintenance/workshop building at 6,000 sq ft; storage/water equipment building at  6,000 sq ft; staff house at 1,176 sq ft;  a lake-side gazebo at 300 sq ft; one water orientated accessory structure 60-foot setback from lake unknown size; several miscellaneous storage buildings and garages.  The plans also include the development of a trail system for hiking and cross-country skiing and the development of ball fields with storm shelters. In addition to the Commercial PUD, “Lot A” is reserved for Hunt’s personal home with garage. 

 

Exhibit 1: 2006 Application for Conditional Use

Exhibit 2: Current Concept Site Plan

Exhibit 3: Lake map showing restricted areas and development location

 

The proposed Commercial PUD would hold a minimum of 150 people and is concentrated on the first two tiers of the shore impact zone. 

 

This part of the plan is referred to as “phase one” on the Living Word Bible Camp website. (Exhibit 4 & 5) The long-range plan submitted in 2001 shows an additional 36 housing units built as 18 duplex units bringing the population density up to 395. 

 

Exhibit 6: original Concept Plan with expansion included

Exhibit 6a: additional floor plans and sketches originally submitted

 

In May of 2001 the EQB granted an EAW petition on this proposed development to representative Jan Monley, 34905 Christmas Lane, Grand Rapids, MN 55744.  The applicants pulled the Conditional Use Permit and proceeded to apply only for the rezoning.  The rezone was denied by Itasca County in June 2001 and has been in litigation until April 2006.  With rezoning finally granted as Seasonal Residential under the 1998-zoning ordinance, they are now applying for a CUP application for a Commercial PUD under the 1998-zoning ordinance, which allows four-tier development and does not require current shoreland mitigation. 

 

Legal Description/Location:  The property is located in Itasca County In Unorganized township 57 Range 26, Lots 2&3, Silver Fox Gardens, NE-SE, Part of Lots 5&6 laying west of Co. Rd 62, Sec. 35, and Gov. Lots 2,3, & part of Lot 4, S. 34, 57-26 Unorganized #45, Dist. 2 

 

Exhibit 7, 8 & 9: Legal descriptions, parcel map, township plat

 

The current land use of this parcel is residential consisting of one single family home, and could be developed into approximately 6 or 7 single-family homes. Previously the land was used as a fox farm.  It is mainly forested with wetlands and has one small open field. 

 

PROPOSER OF THE PROJECT

 

Ron Hunt

Living Word Bible Camp

36186 Baker Road

Grand Rapids, MN 55744

Telephone: 218-327-2355

 

NAME, ADDRESS AND TELEPHONE NUMBER OF REPRESENTATIVE FOR PETITIONERS

 

Holly Newton

34975 Christmas Lane

Grand Rapids, MN 55744

Telephone: 218-326-8303

 

BRIEF DESCRIPTION OF POTENTIAL ENVIRONMENTAL EFFECTS WHICH MAY RESULT FROM THE PROJECT

 

Deer Lake is one of five pilot lakes in Minnesota chosen to serve as a model in the Minnesota Sustainable Lakes Project. This is a model developed around the general goals of sustainable development, which is a process of analyzing decisions in order to find a balance among economic activity, environmental requirements and the social needs of the people.  It is the goal to meet the basic needs of all people without compromising the ability of future generations to use and enjoy a high quality lake resource.

 

Exhibit 10:  Sustainable Lakes Project report

 

The Deer Lake Association adopted a Deer Lake Management Plan in 2000, which reflected the goals expressed in the Sustainable Lakes Plan. 

 

Exhibit 11: Deer Lake Management Plan

 

Water Quality

Deer Lake is an Oligotrophic lake, which means it is a fragile lake as it is low in basic nutrients and has high oxygen content.  Because of this, it doesn’t take much to impact and potentially decrease the water quality and wildlife habitat in and surrounding the lake.

 

This Commercial PUD with a minimum of 150 people per day with initial use planned at 8 weeks of children’s activities will also include family and adult activities such as staff development seminars, retreats and educational conferences on a year-around schedule.  The increased population density and intense use of this area has potential for significant environmental effects on the water quality of Deer Lake.

 

The youth camp/learning and conference center proposed by LWBC would require substantial infrastructure, elaborate septic systems to accommodate commercial lavatories, commercial dishwashers, and commercial laundry.  This has the potential for significant environmental effects on the water quality of Deer Lake. 

 

Jack Jones, a Limnology professor at the University of Missouri describes technical aspects about the potential environmental effects a high density development, such as proposed by LWBC, will have on the water quality of a clear lake like Deer Lake. 

  

“And water clarity is tied to nutrients and nutrients are tied to waste water and if you put more people on a patch of land, you will generate more nutrients and impart more nutrients to a lake.” “A small increase in nutrients in Deer Lake from additional waste water generated on the lakeshore will decrease the transparency” “There is an inflection point that is really critical.  And, small increases in nutrients can cause a drastic decrease in transparency.” (Exhibit 12)

 

 “The source of nutrients is from human activity in the watershed of lakes. In northern lakes, nutrient input to lakes is directly tied to the number of people in the lake drainage basin/shoreline. The mechanisms of nutrient entry into lakes from human activity in the catchments is from surface runoff and septic inputs to ground water. The relationship between human development and lake water quality is well quantified by the science of limnology -- lakes with moderate development will retain their clarity whereas lakes with Planned Unit Developments will be degraded by excess nutrients.”   (Exhibit 13)

 

William Downing, Aquatic Biologist and limnologist on Wabana Lake which is near Deer Lake, has the following to say about the potential environmental effects that a high density development as proposed by LWBC would have for many years in the future on a sensitive lake such as Deer Lake:

 

• Screening houses from the lake in cluster developments does not change the impact

of people and boats on the lake. Habitat destruction occurs from boating and high

use-rates. Septic systems set back from the lake only mean the phosphorus takes a

longer time to get to the lake. It will get there. No free lunch.

• Itasca County lakes are very sensitive to degradation. Once you are able to measure

degradation, it is likely to be too late to restore water quality. Polluted groundwater

continues to flow to a lake for decades after septic systems are removed. Nutrient

rich sediments continue to be stirred up every time the wind blows or a boat speeds

through the shallows. Nutrient rich soils erode whenever the rain falls. Watersheds

have a longer memory than our lifetimes.

• Limnologists have known for 40 years that lakes’ water quality declines directly as the number of people in the watershed increases, that the changes occur slowly and can

be irreversible, and that lakes like those in Itasca County are particularly susceptible

to degradation. (Exhibit 14)

 

 

Wetlands

The LWBC property is part of the only major wetland on Deer Lake.  There is potential for significant environmental effects due to the impact of the buildings, septic systems, trails and large active population density per day.  According to data offered by Art Norton of the Soil & Water Conservation District, Deer Lake is extremely fragile because of the low percentage of wetland (14%) compared to a large majority of lakes (31%). 

 

Exhibit 15: site map with wetlands delineation

Exhibit 16: SWCD land use data for Deer Lake

Exhibit 17: SWCD lake characteristics for Deer Lake 

 

Diverse species of plants, insects, amphibians, reptiles, birds, fish, and mammals depend on wetlands for food, habitat, or temporary shelter.  Although wetlands make up only about 3.5 percent of U.S. land area, more than one third of the United States’ threatened and endangered species live only in wetlands.  (Lake Access, An Impact Metro Project (www.lakeaccess.org) 

 

Exhibit 18: Wetland information

 

The amount and quality of wetlands has something to do with how clean the lakes are. (Lake Access Exhibit 18) Even very small wetland areas can help protect water quality.  U of M Extension Services, Preserving Wetlands, Shoreland Best Management Practices.  

 

Exhibit 19: Preserving wetlands

 

Dr Harold Dziuk, professor emeritus University of Minnesota, expresses that the establishment of a large commercial enterprise on the shoreland of Deer Lake could have significant harmful environmental impacts, not only on the fisheries and wildlife that currently live in the area but on water quality as well.

 “Large numbers of active visitors repeatedly venturing into the sensitive near shore lake, with or without watercraft, will stir up bottom sediments, kill or impair aquatic plants, destroy spawning habitat and impair or inhibit reproduction of the muskellunge. Wildlife species that inhabit the eastern shoreland of Deer Lake require protection from human activity for their survival. Activities associated with nearly daily, year-around use of the shoreland area by large numbers of visitors in a commercial venture is expected to eliminate most of the suitable environment and wildlife habitat in this area.” (Exhibit 20)

 

Fish Spawning

The DNR recognizes the area surrounding this property as one of the most important fish spawning areas of Deer Lake. It is a designated Minnesota State Aquatic Management Area and is one of the few natural Muskie spawning lakes in Minnesota.  This unique area is commonly known as “Kocemba’s Bay”.  It is an aquatic and terrestrial habitat with shallow rock reefs, bogs, islands and a large variety of aquatic grasses and reeds.  It is a diverse habitat for fish and wildlife.  It is a well-known nesting and feeding area for waterfowl such as Loons, ducks, and herons and is habitat to other protected species such as bald eagles and owls. It is also habitat for Timber Wolves, coyotes, bobcats, lynx, bear, red and silver fox to name a few.  It is a designated Minnesota State Wildlife Management Area.  Perry Loegering, the DNR Area Wildlife Manager recognizes the potential environmental impact of this proposed development to the shoreline and the effects on wildlife habitat and fish spawning. 

 

Richard Thompson, DNR Fisheries Specialist, recognizes this area as an important wildlife “quiet” area on Deer Lake. The islands and varied terrestrial and aquatic vegetation in this area provide food, cover, nesting and resting areas for a variety of wildlife and non-game wildlife species. He expresses that wetlands are poor choices for development.  Water quality can ultimately be impacted. Due to the location of the Commercial PUD proposed by LWBC there may be potential for significant environmental effects. 

 

Exhibit 21:  DNR Fisheries

 

Christopher Kavanaugh, DNR Area Fisheries Supervisor, recognizes Kocemba’s Bay as an important fisheries habitat.  Deer Lake presently has an excellent muskie population sustained exclusively by natural reproduction. Deer Lake is one of the only lakes in Minnesota where this occurs.  The marl substrate is particularly sensitive to disturbance.  Marl, by definition, is precipitated calcium carbonate, and is very fine and easily displaced.  Chara is a green algae, essential for spawning, and does not have a defined root system.  Disturbance or destruction of this habitat could be detrimental to the overall health and sustainability of muskies in Deer Lake. Mr. Kavanaugh expresses that the development proposed by LWBC would intensify the potential for environmental impacts. 

 

Exhibit 22: Kavanaugh letter

Exhibit 23: Kavanaugh letter

 

The use of canoes, kayaks, paddle boats, pontoon boats and fishing boats during daily activities by LWBC has the potential for significant environmental effects on the marl substrate and fish spawning area. According to their application, groups of up to 30 children and adults will be canoeing, kayaking, and using motorboats on a daily basis, where presently there are only a few boats per week in this area.

 

Jeff Sundin, a professional fishing guide for 20 years in Itasca County, recently stated that if you disturb or destroy spawning beds in shallow areas, even after spawning is completed, the fish will never come back. (Fish, Water, and Weeds, a Delicate Balance, Thursday April 20, 2006 Itasca Community College, ICTV)

 

Increased Boat Traffic and Surface Water Use

The high densities proposed by the LWBC would have potential to affect the surface waters environment of Deer Lake.  The LWBC proposes an intense commercial use with large groups actively using the lakeshore, swimming, boating, and gaming, most of the time simultaneously.  LWBC proposes water and boat use from 1:00 to 5:00 daily. In Supplementary Report No. 4, The Concept of Cluster Development  (DNR, 1974), The DNR acknowledged that as density increases through clustering the surface waters might overcrowd and that questions existed as to whether a “particular body of water” could “absorb the increased use generated through cluster development.” 

 

Loon Nesting

The development proposed by LWBC has the potential to significantly affect loon nesting on Deer Lake.  

 

Cindy Hagley, Limnologist and ecologist, works with several lake associations and lakeshore communities throughout the State, including Lake Superior, with respect to various shoreland management issues and water quality problems.  Ms. Hagley expresses that the site is a very good loon nesting habitat and important spawning area. The population and activities that the LWBC project proposes, increased boating and canoeing etc. could have potential environmental effects on loon nesting, spawning and other ecological functions in the area.  

 

Exhibit 24: Transcript of Hagley comments 

 

The loon is vulnerable to human disturbance in the vicinity of nesting areas.  Many types of disturbances threaten loons at their breeding sites, including lakeshore development and human recreational disturbance. It was found that disturbance of nest sites by canoeists in the Boundary Waters Canoe Area in Minnesota was the primary factor limiting productivity. Because of vulnerability to habitat loss or degradation, lakes that support breeding loons need protection. Small islands and deadwaters should receive complete protection from development.  Undeveloped buffer zones of at least 492 ft should be left on either side of mainland nest sites or deadwater entrances.  Shoreline areas adjacent to known traditional nursery areas should also be protected, with minimum undeveloped buffer zones of 492 ft from both ends of the nursery. (The Nature Conservancy; species Management Abstract: “Common Loon.”  Protection of loons and their habitat during pair-bonding, egg laying, and initial brood rearing, April 1 through July 15, is important for reproductive success.  Brood rearing areas or nurseries are also important to protect after July 15.  “Campers and other visitors should be prevented from approaching within 492 ft of nesting sites from April 1 through July 15.  A 492 ft disturbance buffer is also recommended for brood-rearing areas (nursery pools) from July 15 to September 1.  Building within 492 feet of a loon nest should be avoided year-round to maintain a permanent buffer around nests.” (Washington Dept. of Fish and Wildlife; Priority Habitats and Species 

 

Exhibit 25: Nature Conservancy abstract on Common Loon

Exhibit 26:  Washington State recommendations on Common Loon

 

Eagles

The proposed LWBC development has the potential to significantly affect the wildlife in the surrounding area.  Mary Blickenderfer, Shoreland Extension Educator, University of Minnesota Extension Service states the following in regard to the development proposed by LWBC   “The estimated users would cause severe, negative impacts to the unique and valuable muskie spawning area that exists along the shore of the property.  Destruction of shoreland habitat that is inevitable with high-density human use would threaten other lake residents, including loons, bald eagles, waterfowl, and migratory song birds.” 

 

Exhibit 27: Blickenderfer letter

 

 Bear Island, which is proximal to the LWBC property, is a well-known eagle-nesting site and was purchased under the Critical Habitat component of the Reinvest in Minnesota Program.   The development proposed by LWBC has the potential to significantly affect this bald eagle nesting area due to increased boat and foot traffic.  Nesting habitat management guidelines prohibit most activities within a primary management zone of 750 to 1500 ft from the nest, and particularly prohibits unauthorized human entry during the nesting season. Activities such as logging and large-scale construction should be prohibited within a radius of 1 mile of nest sites. (Bald Eagle Habitat Model USFS www.fws.gov)

 

Noise

 Megaphones, loud group noises, loud outdoor music, are commonly associated with camp activity. LWBC states that operating hours are 7:00 am to 11:00 pm. Water will not serve as a buffer to the lakeshore neighborhood; instead water will conduct the sounds and has the potential to significantly affect the residential nature of the surrounding neighborhood.  Even with closed windows, sounds from the lake are highly audible.  The large campfire/amphitheater poses significant potential for projecting sound.

 

Traffic

 The proposed development has the potential of significantly increasing the traffic on CSAH 62 and County Road 302.  Dave Christy, Itasca County Highway Engineer, remarks “we believe that it (Road 302) would not “hold up” under the traffic volumes anticipated by the proposed development.”  CSAH 62 is a popular road used by residents for exercise and recreational activities such as bike riding, inline skating, walking, jogging, and horse-back riding.  Increased traffic from staff, campers, visitors, service trucks, buses, has the potential for environmental effects and could significantly impact the public safety of the surrounding neighborhood. 

 

Exhibit 28: Christy letter on traffic

 

Erosion

Extensive clearing of trees and vegetation is necessary to accommodate several large buildings and parking areas proposed by LWBC.  The property includes a bluff area, wetland areas, and a fragile shoreline. Erosion resulting from this project has the potential for significant environmental effects. 

 

 

In conclusion:  Because of the many potentials for environmental effects the commercial Planned Unit Development proposed by LWBC poses on Deer Lake and the surrounding area, an Environmental Assessment Worksheet is being requested by the following citizens: (attached petition)

 

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AMENDMENT TO THE

 

PETITION FOR AN ENVIRONMENTAL ASSESSEMENT WORKSHEET

To determine the impact on Deer Lake by Living World Bible Camp.

 

At the Public Hearing May 10, 2006 of the Itasca County Planning Commission/Board of Adjustment new information was disclosed, this being after we submitted the EAW Petition. It was confirmed that an additional six buildings could be added to this proposed project with no governmental or public input.  Also the applicant stated that an additional wood storage/furnace building was to be added to the proposed project. 

The gross floor space of these added buildings if they are similar to the proposed buildings in the site plan would bring the total gross floor space over the threshold for a mandatory EAW for a commercial/institutional project, such as a youth camp, which is 100,000 square feet of gross floor space in an unincorporated area. 

 

DESCRIPTION OF THE GROSS FLOOR SPACE OF THE PROPOSED PROJECT 

 

Main Lodge: three levels; two @ 9,000 SF mezzanine 2,500 SF   20,500 SF

Five Housing Units: three levels; two @1,827 SF mezzanine 800 SF 22,720 SF

(Each Housing Unit is 4,544 SF)

Office Building: Two levels @1,800 SF   3,600 SF

Gymnasium/Activities:    7,000 SF

Maintenance/Workshop:   6,000 SF

Storage/Water Equipment:   6,000 SF

Existing Staff House: two levels @ 1,176 SF     2,352 SF

Gazebo:       300 SF

Storm Shelter:         300 SF

Water Orientated Accessory Structure: undisclosed

Misc. Storage:         240 SF 

Existing Garage: undisclosed

Unnamed Building on site plan ledger: one level         600 SF

Existing Boat House: undisclosed

Wood Storage: added at public hearing undisclosed

Boiler Building: added at public hearing             undisclosed

Directors lake home and garage: undisclosed

 

Total Gross Floor Space (GFS)                 69,612 SF

(Note: Does not include several buildings of undisclosed SF)

  

Approval of the proposed project will also include six additional buildings of unknown size.  If these were six more housing units at approximately 5,000 SF each, there would be an additional 30,000 SF, which would bring the GSF to 99,612 SF.  If the existing garage were an average size of 1,000 SF this alone would go beyond the threshold without adding the other buildings of undisclosed size.

Another option of five more housing units and a building to house a swimming pool as stated in their possible future plans (Exhibit 4, 5, 6 EAW Petition), at approximately 10,000, another storage building 6,000 or any combination of the above would bring the Gross Floor Space to well over the mandatory 100,000 SF for an EAW.  (Exhibit 29)

 

Minnesota Department of Natural Resources; Division of Fish and Wildlife sent a more recent letter to the Itasca County Planning Commission, after the EAW petition was sent, that “The proposed project would have an intensity of use that could not be supported on this site and should be denied.”  (Exhibit 30)

 

 

PROPOSER OF THE PROJECT

 

Ron Hunt

Living Word Bible Camp

36186 Baker Road

Grand Rapids, MN 55744

Telephone: 218-327-2355

 

NAME, ADDRESS AND TELEPHONE NUMBER OF REPRESENTATIVE FOR PETITIONERS

 

Holly Newton

34975 Christmas Lane

Grand Rapids, MN 55744

Telephone: 218-326-8303

 

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Addendum: 

 

Exhibit 29:  Gregg Downing comments

Exhibit 30:  C.M. Kavanaugh letter to board

Exhibit 31:  Dick Osgood on EAW

Exhibit 32:  Aquatic Management Area in Kocemba Bay

Exhibit 33:  Comments on inadequate septic design