German School project on hold for EAW review
By Scott Carlson
The Twin Cities German Immersion School (TCGIS) will have to wait longer to see if it can proceed with razing its current facility – the former St. Andrew’s Church- and replace it with a new building.
The St. Paul City Council in early March postponed voting on whether to approve some variances for the school’s building plans until its planning department completes an Environmental Assessment Worksheet [EAW] to determine if the project warrants a full environmental impact statement.
The neighborhood citizen group Save Historic St. Andrew’s (SHSA) earlier this month petitioned the Minnesota Environmental Quality Board to conduct an EAW. “We filed an EAW because the TCGIS project will result in an increase of net carbon emissions as a result of demolishing St. Andrew’s and building a new gym and classrooms, rather than repurposing the structure.,” said Bonnie Youngquist, a leader with SHSA. “Simple embodied energy calculation provided by city officials suggested over 2,000 tons would be taken to landfills, not to mention the fossil fuel use, the smell of diesel fuel and oil, road damage, traffic, and air quality impact from heavy construction and demolition in a small area surrounded by dozens of private homes.”
Youngquist added, “The purpose of an EAW is to collect information about the likelihood of significant environmental effects and how they can be avoided or mitigated. The Saint Paul Planning and Economic Department has up to 30 days to decide if an EAW will happen or not.”
But Sam Walling, chairman of the TCGIS board, blasted the SHSA’s EAW petition as “another blatant abuse of the public planning process that again reveals the un-neighborly selfishness of a few NIMBY [Not in my backyard] ‘neighborhood activists’ who would preserve an old building it doesn’t own, literally at the expense of educating public school kids.
“This is the same group that has filed a petition for historic designation over the school’s objection and without notifying the school; filed a lawsuit against the school without notifying the school,” Walling said. He added that SHSA also “opposed the school’s site plan and variance requests at every committee and commission despite the review and approval of professional City staff, then appealed the school’s site plan and variance requests to the City Council,”
Walling concluded, “They [SHSA] have also filed two labor-intensive and costly requests for documents pursuant to the Minnesota Government Data Practices Act. More egregiously, they have threatened TCGIS students twice on their social media pages, for which they have yet to publicly apologize. Hopefully public officials will see through these actions for what they are and move forward with educating kids in an appropriate modern environment by approving our renovation.”
But SHSA leaders left little doubt they also unhappy with TCGIS leaders. “We have appealed to TCGIS to protect and adaptively reuse the former St. Andrew’s church, but the board has refused to consider any option to save the building repeatedly,” Youngquist said. “TCGIS leadership has also failed to address the impact the loss of an irreplaceable historic structure and neighborhood landmark like St. Andrew’s would have on the Warrendale area.”
Youngquist contended that state law requires an EAW for a demolition project like St. Andrew’s with a historic eligibility determination pending. St. Paul’s Heritage Commission voted by 9-1 to confer historic designation on St. Andrew’s.
In response to TCGIS community members who have commented on this article, Save historic St. Andrew’s contends that the TCGIS expansion project will result in an increase of net carbon emissions as a result of demolishing St. Andrew’s and building a new building rather than repurposing the historic church. A simple embodied energy calculation provided by city officials suggested over 2,000 tons would be taken to landfills, not to mention fossil fuel use, road damage, traffic, and air quality impact from heavy construction and demolition in a small area surrounded by dozens of private homes unusually located to the TCGIS site.
“When comparing buildings of equivalent size and function, building reuse almost always offers environmental savings over demolition and new construction.” — from The Greenest Building: Quantifying the Environmental Value of Building Reuse, National Trust study.
According to the Minnesota Pollution Control Agency, more than 80% of Minnesota’s 1.6 million tons of construction and demolition waste ended up in a landfill in 2013. St. Andrew’s demolition would generate thousands of tons of landfill.
A citizen petition request to identify the environmental impact of demolishing a historic resource has merit. So does saving a historic resource that has stood for almost a century, eligible for both local and national historic designation.
For those who don’t know, EAWs are meant for large scale projects with the potential for significant environmental damage. Mandatory categories include: nuclear fuel storage facilities and petroleum refineries—those are literally the first two listed in the statute. The list goes on to include mining, highways projects, and large scale developments, especially for projects outside the seven-county metro. This is because the metro area has existing public infrastructure and a robust review process already in place in the form of zoning, building inspection, etc. The EAW is described in statute as a “short” worksheet, but only in the context of an even lengthier report: an Environmental Impact Study (EIS). EIS’ mandatory categories (again just from the first two categories) include nuclear fuel fabrication facilities, uranium mills, and large electric power generating plants.
The “short questions” on the EAW result in a report in excess of a hundred pages and prepared by multiple RGUs (Responsible Government Units) and even field specialists hired from the private sector. An EAW typically takes 2-4 months to complete. The topics researched include a study of area wells and migratory bird patterns. The idea that a small scale project (the demolition of part existing building for an addition of similar size) located within city boundaries and subject to municipal review should be subject to the same level of review as metallic mineral mining or large new developments on shoreland outside the seven-county metro area is flatly preposterous.
The petition only requires 100 signatures, and it gathered them from a 40-mile radius: as far north as Cambridge, to Farmington in the South, Rosemount in the West, and even Hudson, Wisconsin to the East—a full 80% of the hundred odd signatures came from outside St Paul—all of whom signed stating “significant environmental impacts” that that they would personally suffer from a school remodeling project miles away. The so-called “significant environmental impacts” would be caused by standard construction practices, exhaust from school busses, and, this is a direct quote, from “increased noise levels from higher student population.” This refers to the sounds from children playing on the playground, an activity that happens only on the days and during the limited hours when the school is in use. School children yelling might be an annoyance, but is it an environmental hazard?
The fourth rationale, in a bend of logic worthy of the game of Twister, lists the historic status of the building as the fourth reason for the EAW. While it is true that subpart 31 has a provision for EAW review when a there is a historic resource located within project boundaries, it explicitly stated that subp 31 applies only to resources that are not subject to local historic review. Imagine an Indian burial site in the path of a highway project. Here’s where Twister skills come in to play: the City Council was scheduled this month to determine whether or not the building should be locally designated as a historic site, but that is now on hold because of the EAW petition. Had that meeting been allowed to progress, either outcome would have preempted the EAW on historic landmark grounds. Why? Local landmarks are subject to the review of the local HPC instead of the EAW process, and then of course, had the City Council voted to follow the recommendation of the full Planning Commission and not designate the school, there would be no historic status for the EAW. So we have four very dubious grounds for the EAW, combined with the fact that the EAW stopped the very process that SHSA claimed they wanted: a determination of historic status by the City of St Paul.
[I also made a comment with some of the same points on the 18 Mar 2019 Editorial about coverage of TCGIS and its building project in the Bugle. That comment has not been allowed through moderation. Hopefully this one will not be silenced as well.]
The Minnesota Environmental Quality Board requires that EAW Petition signatories be Minnesota residents or landowners.
I am not sure why the residency of legal EAW signatories was important to broadcast without an explanation. Our EAW met signatory requirements and was approved by the Minnesota Environmental Quality Board. Calling out legal EAW signatures who live outside of D10 seems to be an attempt to suggest that our petition was somehow illegitimate. The irony is that TCGIS student population comes from over 60 zip codes, 90% of TCGIS families live outside of District 10.
The citizen process to request consideration for an assessment review is more than petition signatures. The applicant is required to identify the potential environmental effects due to the project, including the loss of a historic resource.
https://www.eqb.state.mn.us/sites/default/files/documents/Quick%20Reference-Petition%20-%20Updated
This article is factually incorrect. The city’s planning office is determining if an Environmental Assessment Worksheet is needed. It is not at this time completing the EAW to determine if an EIS is needed. The article should also note that fewer than 20% of the signatures requesting an EAW came from St Paul’s District 10. This is merely a delay tactic.
State law does **not** require an EAW. It allows for one, if it is being funded by federal dollars via the Dept. of Interior / National Park Service.
This does not apply to a property that someone hopes will be designated by the City of St. Paul.
I’m not sure that NIMBY is an appropriate tag, as it implies that neighbors are in favor, in general, of a specific development, just not in their immediate area. Many neighbors would oppose this type of density, demolition of historic site, and potential other issues, in any neighborhood.
One question: If the building is purchased with public money, shouldn’t the public have a voice?
TCGIS considered these following options under which the church would remain standing: building to the east of the church; building to the west of the church; building an elevated structure to the west of the church; building onto the end of the classroom wing. All of these options would require parking and site coverages variances far beyond the variances already opposed by SHSA, and building onto the end of the classroom wing would require property that TCGIS does not own and was not able to purchase.
Most importantly, all of these options are unaffordable due to the ongoing maintenance costs of the church.
Ms Youngquist’s statement that TCGIS “refused to consider any option to save the building repeatedly” does not reflect that these options were considered and rejected due to financial considerations.