1231 Minnehaha Ave W St. Paul, MN 55104

February 22, 2019

Environmental Quality Board 520 Lafayette Road North Saint Paul, MN 55155 Citizen Petition requesting an Environmental Assessment Worksheet (EAW) concerning Twin City German Immersion charter School (TCGIS) Expansion To Whom It May Concern: Enclosed is a citizen petition for an Environmental Assessment Worksheet (EAW) review concerning the proposed Twin City German Immersion charter School (TCGIS) Expansion. The major environmental issues where review is requested are: loss of a significant and irreplaceable historic resource, the former St. Andrew’s Church; increased traffic and safety concerns; increased noise levels; lack of on-street parking; and an increased net carbon production. Included are the following documents: project description, discussion of environmental impacts with support documentation, copy of a notification letter sent to the project proposer and public officials, and the required signatures of Minnesota residents using the EQB petition template. Thank you. Sincerely, Roy Neal 1231 Minnehaha Ave W St. Paul, MN 55104

Project Description: The Twin Cities German Immersion charter School (TCGIS) proposes to demolish the former St. Andrew’s church building (or Aula), currently used as a gym and cafeteria, and replace it with an approximate 24,650 s.f. addition (Exhibit 1). The project location is just southwest of Como Lake in the quiet residential neighborhood of Warrendale (Exhibit 8). The total lot is approximately 0.76 acre. The addition includes a gymnasium, kitchen, cafeteria and classroom space. The addition is meant to accommodate an increase more students, from about 580 to 640, and more staff, from 80 to 87. The St. Andrew’s church building is made from concrete, brick, bedford limestone, and terra cotta. The addition would use brick, metal panels, and precast concrete. Project Proposer: Ted Anderson, Executive Director, Twin Cities German Immersion charter School, 1031 Como Ave, St. Paul, MN 55103 Petition Representative: Roy Neal, 1231 Minnehaha Ave W, St. Paul, MN 55104 (651-226-3230)

1231 Minnehaha Ave. W St. Paul, MN 55104

Ted Anderson Executive Director Twin Cities German Immersion School 1031 Como Ave. St. Paul, MN 55103

Dear Mr. Anderson,

You are hereby notified that a citizen petition has been submitted to the Environmental Quality Board (EQB) requesting that an environmental review be considered for the proposed Twin City German Immersion School (TCGIS) expansion.

Respectfully,

Roy Neal 1232 Minnehaha Ave. W St. Paul, MN 55104

Cc: Environmental Quality Board, Mayor Melvin Carter, Senator John Marty, Rep. John Lesch, City Council President Amy Brendmoen, District 10.

Twin City German Immersion charter School (TCGIS) Expansion Potential Environmental Impacts: The expansion of the Twin Cities German Immersion charter School (TCGIS) coupled with the demolition of the historic St. Andrew’s church would create four environmental impacts: 1. The loss of a significant and irreplaceable historic resource, the former St. Andrew’s Church 2. Increased traffic and safety concerns in a small, residential neighborhood 3. Increased noise levels from higher student population, more traffic 4. An increase in net carbon production in close proximity to homes, and an unsustainable plan These issues need addressing and are described below. 1. Loss of a significant, irreplaceable historic resource Current TCGIS expansion plans would require the demolition of the former St. Andrew’s church, a neighborhood landmark since 1927, and iconic example of the Romanesque style. See St Paul Zoning File No. 18-12865 application (Exhibit 1). The expansion plan completely ignores the significance of the St. Andrew’s building, its importance to the community, and its capability to be adaptively reused to meet the needs of the school. The building was designed by Charles A. Haulser, St. Paul’s first city architect, and a protege of Clarence H. Johnston and Louis Sullivan. Respected professionals and organizations have all concurred that St. Andrew’s is worthy of local and national historical designation including St. Paul’s Heritage Preservation Commission (HPC) staff and commissioners, the Minnesota State Historic Preservation Office (SHPO) and an esteemed professional research team hired by Save Historic St. Andrew’s (SHSA). Architectural historians and professionals Rolf Anderson, Barb Bezat, Marilyn Chiat, Alan Lathrop, and Bob Roscoe were hired to complete a detailed historical evaluation and report results (Exhibit 2). They concluded the former church was significant on a number of fronts and worthy of preservation. In fact, the building only needed to be found significant in one of seven key criteria, but was found significant in four. Their report was submitted to the St. Paul Heritage Preservation Commission (HPC) for peer review and assessment of the building’s merits for historical designation eligibility. The HPC was convinced by the report and they recommended historical designation for St. Andrew’s (Exhibit 3). The Minnesota State Historic Preservation Office (SHPO) later concurred that St. Andrew’s would be an ideal candidate for local designation (Exhibit 4). St. Andrew’s is also in the process for National Register historic designation.

In the AIA Guide to the Architecture of the Twin Cities, architectural historian Larry Millett noted that St. Andrew’s is “One of St. Paul’s best period revival churches.” Millett further explained the importance of the building as follows:

“My statement in the guide that St Andrew’s is “one of the St. Paul’s best Period Revival churches” was based on simple observation. I’ve looked at most of the Period Revival churches in St. Paul and St. Andrew’s, by virtue of the quality of its design and its beautiful detailing, certainly deserves a high rank. St. Thomas More (St. Luke’s) Catholic Church (1925) on Summit Ave. and Our Lady of Victory Chapel (1924) at St. Catherine’s University are also outstanding. . .It’s one of the neighborhood’s most important works of architecture and in my opinion qualifies for listing on the National Register of Historic Places as well as local designation.”

Architectural historian Paul Larson states that St. Andrew’s is among the most notable churches constructed in the Twin Cities during the 1920s. He specifically compares the building with two Romanesque Revival style churches built in Minneapolis: St. Boniface designed by Charles Hausler in in 1929, and Holy Cross Church, designed by Cordella and Olson in 1928. He states that St. Andrew’s “. . . is distinctive from the others of its style for the tourelles that flank the entry as part of a deeply sculpted masonry treatment of the façade. It is also the only one that mixes stone and brick, a common element of the Italian sources of the design. . . St. Andrew’s is a magnificent building by any standard and one that absolutely merits preservation.” Thus, St. Andrew’s is not only a significant building in the Lake Como area, but it is also among the most distinctive neighborhood churches in St. Paul, and also an important design when compared to churches from the era in Minneapolis. This according to experts, not just the opinion of SHSA and neighbors whom want to protect the building from demolition. Its loss would be a loss to the city of St. Paul’s architectural legacy. SHSA appealed to TCGIS to protect and adaptively reuse the building, but the board has refused to consider any option to save the building. 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. Instead, they tried to undermine our report findings in an attempt to thwart historic designation. This has taken the form of letters sent to city staff and elected officials, and a relentless push for variances and site plan approval. TCGIS has also argued that only the property owner has the right to nominate a property for historic eligibility, which is untrue. The US Supreme Court decision in ‘Penn Central Transportation vs. City of New York’, established that historic preservation ordinances without owner consent provisions are constitutionally valid and that preservation of historic landmarks is an "entirely permissible goal" for cities. Historic buildings are also protected as resources worthy of protection as any natural resource, under the Minnesota Environmental Rights Act (MERA). Since plans for demolition were made public in March, 2018, SHSA has collected over 600 signatures requesting that alternative solutions for adaptive reuse be seriously considered, rather

than resorting to demolition of historic St. Andrew’s. Many neighbors want to save St. Andrew’s. The threat of demolition is imminent and urgent. TCGIS has tried to perform a partial demolition on the bell tower in October, 2018, but was stopped by the city. They have announced they plan to begin demolition as soon as possible, which could mean anytime between April - June, 2019. Historic designation of St. Andrew’s is appropriate, according to experts and neighbors. But that can’t happen if the building is lost. The impact of losing a neighborhood landmark and an irreplaceable historic resource needs to be assessed in an EAW, especially when there are alternatives to demolition of a historic building that have not been fully explored. A review by the EQB is warranted and justified. 2. Traffic and safety concerns Traffic problems created by TCGIS during pick up and drop off has been a major concern of the Warrendale community for several years, predating the proposed expansion. The proposed expansion will add to the problem, making it critical this issue is addressed now. Warrendale is a small residential community with winding streets. About 90% of TCGIS students live outside the neighborhood, meaning that most of the 640 students and 87 staff will drive or bus to school, pumping hundreds of car and bus commutes through residential streets, and idling dozens of waiting cars a few yards from neighbors’ windows. A traffic study commission by TCGIS was unimpressive. The school site is nestled between homes with only a small parking lot. The new expansion plan will require one of the largest parking variances ever granted in St. Paul, and push more cars onto the street and deeper into the neighborhood. There is no parking for buses. TCGIS’ lot size and location makes traffic mediation a challenge compared to other nearby schools, like Como High School, which have large parking lots. But the fundamental traffic problem is that pick-up and drop-off happens on residential city streets (Van Slyke and Como Avenues) that share the same space with residential and city traffic. There are speeders, children darting, distracted drivers, parents speeding out of pick-up and drop-off zones, and more threats to public safety. Students frequently cross the city streets to go to Como Park, or Warrendale Church across the street, creating opportunity for tragedy. All of this makes for a bad traffic situation for both students and drivers. The DT 10 Como Community Council Application for Appeal said it best (Exhibit 7):

“The site plan that would take effect because of the Planning Commission’s actions does not address inadequacies that city staff and independent consultants have identified concerning traffic flow, student drop-off and pick-up, bus parking, crosswalk treatments, a Safe Routes to School plan, and related issues affecting congestion, parking, pedestrian safety and the impact of vehicles on the surrounding neighborhood. It does not incorporate the findings of a traffic impact analysis the city’s traffic engineer deemed necessary. The site plan that is being allowed to take effect places no conditions

upon the school or city departments to address these impacts, as is required by city code.”

There has been no opportunity for community input, review, or public discussion of TCGIS’ traffic plan, which was conducted by Spack Consulting on December 10, 2018. This report was steamrolled through the Planning Commission in an irregular way that drew attention from the City Attorney’s Office. An independent review of traffic safety and control by the EQB, DT 10, Metro Transit and the Warrendale community is warranted and justified. Exhibit 9 shows how a typical day is congested, has decreased visibility, and poses traffic and pedestrian safety issues. 3. Increased Noise: The TCGIS school location and site plan is unique in that the school is located next to private homes rather than being on a separate block. The outdoor gym area is within 10 feet of a home. Because of the number of students, there have been many noise complaints from near-by neighbors. Noise from the students is reflected off the brick and stone buildings and into the neighborhood. The increased activity level around the school also adds noise to this small residential neighborhood. Historically, St. Paul has not enforced any noise limits on TCGIS. However, in an email from the MPCA about noise limits from October 2018, the MPCA does have noise level limits for schools (Exhibit 5). TCGIS is proposing a simple 6-foot high, wood fence along the east side alley property line to abate noise, without having done any noise level reduction calculations. No engineering testing data has been shared that validates that a simple wood fence will work to reduce noise from 640 kids an alley-width away from a private residence. Adding a major expansion to a school without validated noise controls is unprofessional and incorrect. A District 10 officials stated “The site plan that would take effect because of the Planning commission’s actions does not address the impact of sound from the school’s play area on nearby residences, as required by city code….” (Exhibit 7). An engineering report signed by a registered engineer with experience in noise control and testing is needed, which describes the following: sound testing methods and levels measured at surrounding private property lines, discussion of alternative noise control methods and recommendations to ensure compliance with MPCA and EPA noise limits. We expect noise levels to increase with the student population, so a review of increased noise levels and control by the EQB is warranted and justified.

4. Increased net carbon emissions: SHSA believes that 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. A 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. Hundreds of older buildings have made energy efficiency improvements to their building envelope and boiler and water heater systems to reduce energy costs and increase building life. TCGIS has not upgraded the mechanical equipment and insulation of the historic building (Exhibit 6), using the excuse of high maintenance costs, in order to self-justify a new building. The project is unsustainable and is not “green.” Once the smoke clears, the project will have created a carbon footprint that could take generations to undo, according to a 10-year landmark study by the National Trust for Historic Preservation, The Greenest Building: Quantifying the Value of Building Reuse:

“It can take up to 80 years for a new energy efficient building to overcome, through efficient operations, the climate change impacts created by its construction.”

TCGIS claims they tried adaptive reuse by converting the church sanctuary into a gym, but we have pointed out that as a sustainable practice, adaptive reuse in not meant to be temporary, only until demolition starts. SHSA believes that this project is unsustainable and should be measured to see how bad it really is. It is requested that TCGIS complete a net carbon emissions balance, by a registered engineer with experience in carbon balance calculations along the whole materials and activity chain of the project. A review of net increased carbon emissions by the EQB is warranted and justified. LIST OF EXHIBITS 1. TCGIS Site Plan review application (St Paul Zoning File No. 18-12865). 2. Historical Report on St. Andrews, Rolf Anderson and others, October 2018. 3. St. Paul Heritage Preservation Commission Findings on St. Andrew’s. 4. Minnesota State Historic Preservation Office letter on St. Andrew’s. 5. MPCA Noise Limits & Regulations for Elementary Schools, MPCA, Oct 29, 2018. 6. Maintenance Items & Costs Slide (Roof, boiler, water heater, insulation etc.), TCGIS 7. District 10 Community Council, ‘Application for Appeal’, February 19, 2019 8. Site Plan Map 9. Traffic Map & Images