Greenhouse Gases
A required element of the Environmental Assessment Worksheet (EAW) is an analysis of the project on greenhouse gas (GHG) emissions. The EAW for the arena failed to examine the two most important aspects of the project — the building and its users —when addressing the GHG issue. This is one reason that ARD is asking the Court of Appeals to require an environmental impact statement.
Our federal, state, and city governments all have a policy to reduce GHGs. UST has its own policy to minimize GHGs. Yet the EAW merely described the harmful effects of greenhouse gas and intentionally did not address mitigation. Specifically, the EAW admitted it was not addressing the GHGs emitted by the arena’s cooling systems, stating (at 32) that “Emissions from cooling and refrigeration systems are not accounted for in this operational emissions analysis as GHGs from refrigerants are approximately less than 5 percent of the total GHG emissions of a building.” But this is not an average building. The arena will have two ice rinks and will need to keep them frozen, despite warming the arena for the comfort of spectators. The arena’s massive heating and cooling systems will work against each other and spew GHGs into the environment. Because the EAW did not analyze these emissions, it is deficient.
The EAW also fails to analyze the GHGs emitted by the spectators as they travel to and from the site and drive around the neighborhood looking for parking. Because UST’s parking supply will be short, 2,000 vehicles will be circling the neighborhood in search of parking. On weekday nights, that parking does not exist because most streets require permits until 8:00 pm. They will therefore continue to drive the streets, going further from the arena until they find a street where St. Thomas parking had not been a problem before, and they will fill that street with their cars. But in time, those residents will petition for permit parking and spectators will park even further away.
The EAW ignored GHGs emitted by the building and by cars. Overlooking the placement of two ice rinks and their resultant GHG emissions is obviously problematic. Car emissions are more diffuse but cumulatively massive; “Transportation is responsible for approximately 31% of emissions in Saint Paul” (St. Paul Climate Action & Resilience Plan, at 55). The Minnesota Court of Appeals recently overturned a municipality’s failure to require a full environmental impact statement where an EAW did not evaluate the emissions of spectators arriving and departing. In re the Need for an Envtl. Impact Statement for the Mankato Motorsports Park, No. A23-0091 (Minn. App. 2023).
When greenhouse gas emissions are analyzed in an EIS, it will be impossible for UST to deny that an arena of this scale does not belong on the banks of the Mississippi River, in a residential neighborhood, and the City of St. Paul will not permit this environmental damage.