City council sends comments to MnDOT about Highway 23

The city council also included diagrams of their alternatives with their comments.)

Over the past few years, the City of Paynesville has attempted to work with the Minnesota Department of Transportation (MnDOT) to create a project that met all of MnDOT's goals and criteria for the Trunk Highway (TH) 23 bypass project, as well as meet the needs of the City. As we have indicated over the past few months, it is very unfortunate that the project is at this stage of development and (that) there are still issues that remain with reference to the Paynesville Municipal Airport.

While the TH 23 bypass project is very important to the City, the airport is also very important to the City now and into the future. Based on this information, we feel that as a City, we need to comment on the Final Environmental Impact Statement (EIS) to express our concern regarding the conflicts that exist between MnDOT Highway and MnDOT Aeronautics/FAA (Federal Aviation Administration).

Based on our review of the Final EIS and the meetings that have been held for the project, we would like to present the following questions and comments regarding the TH 23 bypass route with reference to the Paynesville Municipal Airport:

1. Why doesn't the final EIS address the impacts and mitigation actions that are necessary since the TH 23 Bypass route is located in Zone A of the Paynesville Municipal Airport's Zoning ordinance? This issue leads to the following concerns:

a. According to the City's airport zoning ordinance, no structures should be located in Zone A. Zone A is identified on the attached drawing. As shown on the drawing, the bypass route is located within this zone. It is believed that MnDOT Aeronautics and the FAA will accept the new highway mainline alignment to be located in Zone A if 10:1 side slopes are provided along the highway to help mitigate the placement of the structure in this zone. In addition, the City Council and the Airport Commission will also need to approve the placement of the highway in Zone A.

b. No other structures should be located in Zone A, including signs, light poles, signal poles, and fences. This creates a concern with the ramps that are currently located within Zone A. Since lighting and signs are typically located at ramp locations it may be very difficult for the ramps to remain at the current location.

c. The locations of the ramp along the north/east bound lane of the proposed TH 23 are located in the center of Zone A of the airport. This creates concerns with headlights from vehicles shining down the runway and possibly interfering with a pilot's vision.

2. Why doesn't the final EIS accurately reflect Zone A of the Paynesville Municipal Airport? For example, Figure 2-2 appears to show the runway protection zone rather than Zone A.

3. Why doesn't Section 3.2 - Land Use - in the final EIS address the Paynesville Airport Zoning Oydinance, nor the impacts and mitigation plan related to the ordinance? Also, the proposed TH 23 bypass project will directly impact the future expansion of the airport. How will the property that will be taken for the bypass project be replaced in order to provide for future expansion of the airport?

4. Why does the final EIS indicate that construction will start in 2017 when we have been told that construction was planned to start in 2010 at the latest?

Overall, the final EIS does not address the potential impacts to the Paynesville Municipal Airport that will result from the construction of the proposed TH 23 Bypass project. Preservation of the airport and safety of the airport users are very important issues to the City.

If the final EIS adequately considered the impacts and mitigation efforts with reference to the Paynesville Municipal Airport, most or all of the concerns that have been expressed by MnDOT Aeronautics and the FAA would already be addressed. As you are aware, MnDOT Aeronautics and the FAA have indicated that there is a potential loss of funding to the airport if the highway project proceeds without resolving or mitigating their concerns.

The potential loss of future FAA funding is a significant issue for the City. The City of Paynesville will not support, nor be responsible for any loss of FAA funding.

In order to help mitigate the unresolved conflicts that exist between MnDOT Highway and MnDOT Aeronautics/FAA, the City has decided to formulate options that we feel are potentially viable and resolve the conflicts.

These options are shown on the attached sketches. We realize that some of these options may have already been explored at some point in time; however, we would like each addressed for the record. Has each been considered, and if so, why has each been disqualified?

The following is a brief summary of each of the attached alternates:

1. Alternate 1: This alternate consists of changing the proposed interchange at (new) First Street (Cemetery Road) to an at-grade intersection with a signal. MnDOT Highway has indicated in the past that they do not want a signal at this location; however, this alternate would eliminate the concerns regarding the airport and create a full access intersection.

This alternate also would save substantial money by eliminating an interchange. As documented in a recent newspaper article, MnDOT Deputy Commissioner Lisa Freese said, "It's essential we find and focus on low cost solutions we have available to us."

This is the preferred alternate by the City of Paynesville.

2. Alternate 2: This alternate creates a full interchange by providing an off ramp and entrance loop in the northwest and southeast quadrants of the interchange (at First Street/Cemetery Road). In addition, an auxiliary lane could be added on the westbound lane to help mitigate concerns regarding the interchange spacing with TH 55. As shown on the sketch, the loops are on the acceleration portion of the interchange rather than on the deceleration. This option moves the ramps out of Zone A of the airport. This alternate, along with Alternate 3, are the second most preferred alternates of the City.

3. Alternate 3: This alternate is similar to Alternate 2; however, the ramps are located in the southwest quadrant rather than the northwest quadrant for the westbound lane. Once again, this alternate would provide a full interchange at First Street and move the ramps out of Zone A of the airport. As mentioned above, this alternate, along with Alternate 2, are the second most preferred alternates of the City.

4. Alternate 4: This alternate consists of a full diamond interchange with the addition of auxiliary lanes to mitigate the concerns with spacing of this interchange with the TH 55 interchange. The auxiliary lanes could possibly be deleted if the TH 55 interchange was redesigned to be fully on the north side of TH 55 as shown in the draft EIS. This alternate removes the ramps from Zone A of the airport.

5. Alternate 5: This option is the same as Alternate 4, except the on ramp for the eastbound lane was eliminated.

6. Alternate 6: This option is the same as Alternate 3, except the loop onto the eastbound lane was eliminated.

7. Alternate 7: This option consists of creating a half interchange at TH 55 and First Street and connecting the interchanges with frontage roads. This would address the interchange spacing concerns. This alternate removes the ramps from Zone A of the airport.

As we mentioned above, the TH 23 project and the Paynesville Municipal Airport are both very important to the City of Paynesville. We are committed to a successful highway project that will protect the integrity of the airport for many years to come.