Camp Coldwater Coalition
A non-profit community-based advocacy group dedicated to preserve and
protect the natural resources and restore the cultural integrity of the
Camp Coldwater area, and to acquaint all people with the historic Birthplace
Preserve Camp Coldwater Coalition
December 19, 2000
Minnesota Department of Transportation
Attn: Richard A. Stehr
1500 West County Road B2
Roseville, MN 55113
Dear Mr. Stehr:
Thank you for your response to the Preserve Camp Coldwater Coalition's
letter of October 24, 2000 as requested by Governor Ventura. It is most
heartening to see the Governor, Senator Paul Wellstone, Mayor Sharon Sayles
Belton, and so many others, take a renewed interest in preserving historic
Camp Coldwater and Coldwater Springs.
As noted in your letter,
the Coalition requests that MnDOT stop work on its TH 55/62 interchange
project due to concerns initially raised by consulting hydrologist Kelton
Barr and then independently verified by Dr. Donald I. Siegel for the Minnehaha
Creek Watershed District (MCWD). These concerns focus on documented impacts,
both temporary and permanent, to the quantity and quality of the water
flowing to and from historic Coldwater Spring caused by MnDOT's interchange
Mr. Barr is not alone in expressing these continued concerns. They are
shared and voiced by the managers, staff and engineers of the MCWD, the
Lower Minnesota River Watershed District (LMRWD), the Mn/DNR, various
consultants, the Coalition, and many other individuals and groups who
are aware of the sensitivity of this threatened historic natural resource.
Minneapolis Mayor Sharon Sayles Belton and others have expressed their
concern directly to Transportation Commissioner Elwyn Tinklenberg.
MnDOT developed an alternative ponding configuration in an attempt to
address these concerns. Unfortunately, MnDOT's alternative will only lessen
the impacts, not eliminate them.
Your second paragraph states "Many thorough studies have been made concerning
the construction of the TH 55/62 interchange. The studies all conclude
that there will be no permanent effect on Coldwater Springs." This is
false. The MCWD emphasized this point in their November 29, 2000 letter
to you in addressing the inaccuracies contained in your November 16, 2000
letter to the Coalition. The MCWD letter also states that "the potential
for a problem, as reiterated by Kelton Barr, continues to exist" and that
studies "clearly show that concerns about the reduction in flow to the
spring are well founded.".
The attached Summary of Documents Finding Impacts to Coldwater Spring
demonstrate that MnDOT's TH 55/62 interchange and ponding plans, including
MnDOT's alternative design, will impact the quality and quantity of water
flowing to and from historic Coldwater Springs. MnDOT has provided nothing
in writing to substantiate their sole counter claims of no impact to Coldwater
Your letter continues: "The project has been approved by all necessary
parties." The MCWD Managers have not approved MnDOT's TH 55/62 interchange
or ponding configuration. Coldwater Springs lies within their jurisdiction.
They believe, and have shown, that MnDOT's project will impact the very
resource they are charged to protect. But their voiced concerns have been
ignored in the approval process. This is unacceptable and in conflict
with the May 24, 2000 Order of the Minnesota Board of Water and Soil Resources
(BWSR) which established the joint MCWD and LMRWD jurisdiction of the
Camp Coldwater watershed.
In its Order, the BWSR Board emphasized "the importance of ground water
and the paramount importance of the protection of Camp Coldwater Spring."
It further directed the LMWD to coordinate with the MCWD to avoid any
possible adverse impacts of the MnDOT construction on the spring.
The LMRWD ignored this BWSR directive at its November 15, 2000 meeting
in granting MnDOT its permit for Alternative #1. The LMRWD also ignored
the MCWD's communication of concern and documentation of certain impact
to Coldwater Springs by MnDOT's alternative configuration. At that meeting,
the LMRWD relied solely on the verbal assurances of Daniel Dorgan, MnDOT
Mr. Dorgan stated to the LMRWD Board "It is still our position that the
original pond design does not impact Coldwater Springs. And any of the
three alternative designs, similarly, will not impact Coldwater Springs."
The LMRWD Managers then failed to ask Mr. Dorgan to substantiate his claim
Rather than presenting evidence to back up his claims, Mr. Dorgan then
committed the taxpayers of Minnesota to "repair" any damage to Coldwater
Springs after the impacts are realized, now or in the future. MnDOT should
not gamble taxpayer dollars to insure a plan only MnDOT believes will
do no harm to Coldwater Springs. Rather, MnDOT owes it to the taxpayers
of Minnesota to spend a fraction of that future fix money now to absolutely
ensure the safety of Coldwater Springs.
MnDOT's planned elevation of the TH 55 reroute once threatened to impact
Coldwater Springs. Then, as now, it was Kelton Barr and the MCWD Managers
who brought this to light. The threat was resolved using the common-sense
approach of raising the roadbed four feet. This small change eliminated
the need to cut into the fragile underground recharge area of Coldwater
Spring. It was a brilliant application of a simple solution to an imminent
threat to Coldwater Spring. We commend MnDOT for recognizing and doing
the right thing then by raising the roadbed elevation to save Coldwater
It is time for MnDOT to once again acknowledge the problem and do the
right thing. The Coalition, and many others, now believe that MnDOT must
reapply this simple and proven model to the TH 55/62 interchange. The
threat to Coldwater Spring will be eliminated if MnDOT adequately raises
the elevation of the interchange. By once again applying this common-sense,
low-cost solution, MnDOT will not only save Coldwater Springs but will
also save Minnesota taxpayers the increased cost of interchange redesign
and reconstruction in the more-expensive future.
The Preserve Camp Coldwater Coalition calls on the BWSR Board to enforce
its directives to the LMRWD and MCWD. BWSR must ascertain that its decision
to create the conflicting jurisdictional alignment between the MCWD and
LMRWD poses no threat to Coldwater Spring.
The Coalition calls on the MCWD Managers and staff to continue its advocacy
work to protect the cultural and natural resources of historic Camp Coldwater
and Coldwater Spring. We also recommend they insist on full and complete
cooperation with the LMRWD to reach agreement on cross-jurisdictional
The Coalition calls on the LMRWD to work in concert with the MCWD. Its
unilateral actions must stop. Any action or decision involving historic
Camp Coldwater and Coldwater Springs must be made with the full support
and approval of the MCWD. To do otherwise is to threaten Coldwater Springs.
In light of this, the Coalition further requests the LMRWD to reopen the
TH55/62 interchange permit process for MnDOT to substantiate its claims
and to reach concurrence with the MCWD and DNR regarding impacts to Coldwater
The Coalition calls on the DNR to come forward and voice their known concerns
over MnDOT's interchange configuration and its impacts to Coldwater Springs.
The Coalition again calls on MnDOT to stop construction now on the TH
55/62 interchange project until concurrence is reached with all parties
that MnDOT's plans are environmentally and fiscally sound and will not
harm historic Coldwater Springs.
MnDOT must make public any study or analysis that show the current TH
55/62 interchange plans will do no harm to Coldwater Springs. MnDOT's
analysis, if it exists, must withstand the scrutiny of peer review as
have Kelton Barr's. MnDOT must convince all agencies and individuals named
jointly in our correspondence that MnDOT's TH 55/62 interchange project
will do no harm to Coldwater Springs. The project must stop until all
parties concur with MnDOT's claims of no adverse impact to Coldwater Springs.
The Coalition calls on Governor Ventura to coordinate the various factions
of state government to work together to develop an interchange configuration
that each and every party can attest will do no harm to historic Coldwater
Please feel free to contact me to discuss these issues and our requests
for action. The Coalition stands ready to assist with any effort to ensure
the continued flow of historic Coldwater Springs.
Preserve Camp Coldwater Coalition
cc Governor Jesse Ventura
Commissioner Elwyn Tinklenberg, DOT
Commissioner Allen Garber, DNR
Ron Harnack, BWSR
Eric Evenson, MCWD
Kevin Bigalke, LMRWD
Robert Winter, MnDOT
Senator Paul Wellstone
Mayor Sharon Sayles Belton
Attachments: Summary of Documents Finding Impact to Coldwater Spring
September 29, 2000 MCWD Resolution of No Impact to Coldwater Spring
November 15, 2000 Letter Mayor Belton to Commissioner Tinklenberg
November 16, 2000 Letter Richard A. Stehr, MnDOT to the Coalition
November 29, 2000 Letter MCWD to Richard A. Stehr, MnDOT
Preserve Camp Coldwater Coalition
Page 4 of 4
Summary of Documents Finding Impacts to Coldwater Spring from MnDOT's
TH 55/62 Interchange Preserve Camp Coldwater Coalition
1. 9/12/00 Kelton Barr Memorandum to MCWD "My calculations ? indicate
that the construction dewatering and the
stormwater pond in the southwest clover leaf of the interchange, called
the S.W. Loop Pond, could divert permanently one third or more of the
flow to Camp Coldwater Spring."
2. 9/13/00 MCWD Letter to Daniel Dorgan, MnDOT Written by MCWD to alert
Dan Dorgan and MnDOT to the issue "concerning
the potential groundwater impacts from the Highway 55/62 interchange and
related construction." and why they believe the impact will be significant,
resulting in a diversion "in excess of 18 million gallons of groundwater
each year that otherwise would flow to Camp Coldwater springs.
3. 9/28/00 Dr. Donald I. Segiel Letter to MCWD
Peer review of Kelton Barr report that states "In conclusion, I agree
with Kelton Barr (2000,a) that normal flow to Coldwater Camp Spring may
be seriously inhibited by dewatering the unconsolidated sediments at the
interchange area. I also believe that the SEH (2000) study was sufficiently
flawed that a more rigorous analysis of the potential impact on spring
volume is not possible from the data available at this time.
4. 9/28/00 MCWD Staff Memorandum to MCWD Managers
Segiel concurs with Kelton Barr's September 12, 2000 report. He agrees
that Mr. Barr's estimate of a flow reduction of 33 percent is plausible."
5. 9/28/00 Michael E Schoenberg Hydrogeologic Report.
Raised concerns that "the drainage pond will intercept groundwater flowing
from the west that would have reached Camp Coldwater Spring. Second, groundwater
to the east of the pond that would have flowed to Camp Coldwater Spring
will flow into the drainage pond."
6. 9/29/00 MCWD Resolution
Requests that MnDOT, LMRWD, BWSR and DNR "ensure that the Spring suffers
no adverse impact" and "of MnDOT that construction of the permanent pond
and any related features, in any respect that may affect flow to the Spring,
be discontinued until investigation is complete and actions to ensure
no adverse impact to the Spring are decided on."
7. 11/6/00 MCWD (Michael Panzer, P,E., P.G.) Letter to Dennis Larson,
"The original pond design, all of the alternative designs and the road
subgrade design will permanently lower the shallow groundwater. The shallow
groundwater gradients in the intersection area will also be altered. The
MCWD has the concern that this could translate to a reduction in flow
from Coldwater Spring and the associated seeps near the spring." "How
much this will affect flow from the spring is unknown."
8. 11/10/00 MCWD Letter to Dennis Larson
"the Board concluded that it does not find Alternative 1 acceptable. In
light of the commitment of the LMRWD and MnDOT, in the boundary change
proceeding, to ensure the protection of flows to the spring, and BWSR's
explicit reliance on that commitment to support its boundary change decision,
it is the Board's view that the stormwater pond should be designed to
have no impact on the spring."