© 2023 by Neighbors for a Livable Saint Paul

Dear Ms. Mohan and Members of the Department of Planning and Economic Development,

 

My name is _____________________, and I live at __________________________ in Saint Paul.

 

I am very concerned about the environmental and community impacts of development at the Ford site. I request that the following possible development scenarios also be considered in the AUAR to provide a better comparison of impacts with those of the current proposal: 

 

1.  The no-build scenario (implying minimal construction and build-out at the Ford site, with the proposed housing being  instead distributed at various infill locations across St. Paul, and much of the Ford site instead used for park, recreational, and wildlife habitat). This scenario is more consistent with the incremental development model of making modest investments over a broad area over a long period of time. The incremental development model stresses the use of existing infrastructur  in the city.

 

2.  A moderately-high-density mixed-use scenario 
     1500 dwelling units          
     94,000 sq. ft. of GFA retail/service         
     125,000 sq ft. of GFA office/employment 
     31,000 sq. ft. Of GFA civic/institutional
     (Note that this housing density is still well above what was
     originally considered by the City when evaluating alternatives
     in 2007). 

 

3.  The Ford Master Plan Minimum scenario as outlined in City documents
     2400 dwelling units
     150,000 sq. ft. of GFA retail/service
     200,000 sq. ft. of GFA office/employment
     50,000 sq. ft. Of GFA civic/institutional

 

For the following reasons, any and all of the above scenarios are environmentally superior to the scenarios already identified in the AUAR scoping documents:

  • These suggested scenarios would imply smaller and fewer buildings, more green space, and fewer trips into and out of the development. This implies reductions in noise, traffic congestion, pollution, and impacts to wildlife and infrastructure.

  • These scenarios would be more easily accommodated by existing street grids, adjacent arterial streets, and existing transit systems. This means a reduction in need for road improvements, and reduced exacerbation of already-existing problems of traffic congestion and resultant air pollution.

  • These scenarios are more compatible with existing land use of the surrounding area, which is primarily low to medium-density residential with accompanying limited commercial development.

  • All of these scenarios will have reduced impact on the Mississippi River Corridor Critical Area (MRCCA), designated as a state critical area to protect its many unique, natural, and cultural resources and values.  This will help preserve vistas of the river bluffs, and have less impact on the more than 325 bird species that migrate along the Mississippi Flyway.  

  • All of these scenarios allow a reduction in the negative impact to the Mississippi River gorge wildlife habitat. The gorge is home to a large variety of large and small mammal species. Other wildlife habitat impacts would also be reduced; for example, the lower-density scenarios would present less disturbance to bald eagle nesting habitat

  • Although social benefits are not explicitly addressed in the AUAR, consideration of lower-density Ford site alternatives is important with respect to the overall benefit to the city. Incremental and dispersed infill development across the city distributes City financial and infrastructure support to parts of the city that may need it more, and tends to be more long-lasting and financially sound for the community.         

  • Including lower-density scenarios in the AUAR will provide greater contrast for comparison with the City and Ryan proposals.  The City’s scoping document includes only two (high-density) development scenarios which are nearly identical. 

 

In addition, the AUAR scoping document implies that minimal consideration will be given to several important relevant environmental issues. I request that additional consideration and study be applied to the following AUAR topic areas: 

Contamination/Hazardous Materials/Wastes (Section 12) — After reviewing initial pollution studies of the Ford property, The Friends of the Mississippi wrote a letter to the Minnesota Pollution Control Agency on July 14, 2017, warning  of “understated water quality contamination at the site and a significant risk of future contamination to groundwater and the Mississippi River that is not adequately addressed in the Report.”  Their concerns relate to Area C, which is adjacent to but not included in the Ryan plans for development.  There has been no specific plan published for the mitigation of this polluted site, however, the pollution there may have direct and/or indirect impacts to the Mississippi River and to area residents. An evaluation of potential environmental impacts of Area C should be included in the AUAR study.

Air (Section 16) —The AUAR scoping document indicates that the vehicle emissions analysis is limited to measuring carbon monoxide (CO) impacts of the project’s traffic generation, and that no further air quality analysis is anticipated for the AUAR. Given the current environmental concern over CO2 in the atmosphere, and given that the underlying purpose of this high density development is to reduce car use and harmful emissions, it would seem logical and prudent for the AUAR to include a more thorough study of vehicle emissions and their health impacts, comparing current and future development scenarios. The emission of particulate matter associated with idling cars in traffic congestion is of particular concern and should be included in this testing.

Noise (Section 17) — The scoping document suggests that additional vehicular traffic generated during construction and resulting from the completed project will be well below a sound increase that would be noticeable, and that no further noise analysis will be conducted as part of the AUAR.  It is all but impossible that noise generated by a project of this scale will not be noticeable. Please include in the scope of the AUAR study an evaluation of potential increase in noise due to construction, and post-project sources of noise including additional traffic, air handling units, and ongoing commercial and maintenance activities at the site. 

Transportation (Section 18) — Vehicular traffic in this area fluctuates dramatically depending on the time of day, time of year, and weather conditions.  It is important that the traffic study accounts for all of this. For example, traffic increases when school is in session, and significant traffic is generated by commuters to the local public and private universities, as well as to area public and private primary and secondary schools.  The traffic study should also take into consideration the additional truck traffic visiting the site; private residence and commercial deliveries, trash and recycling, maintenance, mail, city busses, school busses, etc.

As has been noted, the impact of additional traffic extends outward from the Ford property toward arterial streets, highways, and freeways. The AUAR traffic impact study should be expanded to include:  Cretin Avenue to I-94, Cleveland Avenue to I-94, Fairview Avenue in both directions to the freeways, Montreal to 35E, Randolph to 35E, Mount Curve Boulevard, Mississippi River Boulevard, and Ford Parkway along 46th to Hiawatha Avenue.

Impact on infrastructure and services — The AUAR study should include an evaluation of the impact that all proposed scenarios will have on traffic infrastructure, including the effects of construction and service vehicles on existing roads and infrastructure. It should also address the effects on city storm and sanitary infrastructure, to include increased needs and costs for both storm and sanitary water treatment.

In addition, the AUAR study should include an evaluation of how the added density will impact the social infrastructure — existing and future community access to libraries, park and recreational facilities, schools, transportation, police, fire fighting services, etc.  The AUAR study should also address the economic impacts of supplying and maintaining infrastructure and services. 
 

Thank you for your consideration. 

AUAR Comment Template

Give your Public Comments on the Ford Site Alternative Urban Area Areawide Review (AUAR) by July 10, 2019