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SPEECH Speaks Out on Old Brewhouse Redevelopment

Tim Smith, AICP
Planning Manager, City of Tumwater
555 Israel Rd. SW
Tumwater, WA 98501

October 18, 2014

Dear Mr. Smith:

The board of directors of the South Puget Environmental Education Clearinghouse (SPEECH) decided that we would write a public comment letter on the scope of the EIS for TUM-14-0741 regarding the redevelopment of what has become known as the Old Brewhouse property.

The South Puget Environmental Education Clearinghouse (SPEECH) is a 24 year-old, non-profit that provides support and resources to those who seek to preserve, protect and restore the environment.

We are very concerned about development activities on the land in question. It is situated on a very valuable and environmentally sensitive area on the shores of the Deschutes River at the head of what is now Capitol Lake but was formally an estuary. In order to adequately assess the environmental impacts of this project a number of considerations must be made.

We believe that full consideration needs to be given to WAC 197-11-444, Elements of the Environment. None of the three proposed alternatives appear sufficient to meet this standard.

Here are our suggestions for your consideration:

1. Estuary: Although the water bodies adjoining the Old Brewhouse are currently the Deschutes River and part of Capitol Lake, it is historically an estuary where the Deschutes River entered Budd Inlet. The issue of whether or not to remove the 5thallow Capitol Lake to return to being an estuary has not been resolved. Scientific opinion supports this change. When the estuary is recovered, then this has to be a consideration when assessing the environmental impacts of the redevelopment of this area. Estuaries are critical habitat for species reproduction and survival.
2. Groundwater: It is readily apparent to anyone visiting the Old Brewhouse that there is an amazing abundance of groundwater pouring forth from the hillside behind the building. When the Old Brewhouse was built in 1905 it was surrounded by a moat that provided a means of containing and diverting this groundwater into a large cistern beneath the building. The water-saturated slope behind the Old Brewhouse does not seem to provide a good footprint for a large (625 - 1,000 car) parking garage. As a matter of fact, the entire Old Brewhouse sits on water.
3. Habitat: Capitol Lake provides habitat to various fish, water fowl, river otters, and other aquatic and terrestrial species. If it is restored to being an estuary then it will be even more critical in the life cycles of these species. Any proposed redevelopment of this area would have a serious negative impact on the habitat value of the area. This needs to be taken into account.
4. Cumulative Impacts: The project being considered appears to fall under the National Environmental Protection Act (NEPA) rather than SEPA. This is because under the Endangered Species Act (ESA), it is a navigable, salmon-bearing waterway, flowing directly into the ocean. Granted the Chinook that go to the Deschutes hatchery are not a natural run, but the Coho that go to Percival Creek are native. Because of a gate at Percival Cove that was placed there by the Washington Department of Fish and Wildlife some of the Coho head up the Deschutes River. This means that cumulative impacts have to be considered under the ESA. Cumulative impacts are defined in the NEPA as, "the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time. (NEPA, 40 CFR 1508.7)"
5. Project Placement: With today's zoning and land use laws and regulations, the placement of a major industrial facility on the banks of an estuary would not have been allowed. In fact, under the 1899 federal Rivers and Harbors Act, it became illegal to excavate, fill, or alter the course, condition, or capacity of any port, harbor, channel, or other areas within the reach of the Act without a permit. The Old Brewhouse, constructed in 1906, is on fill. We should not redevelop the area to not only maintain but actually enlarge the scope and thus the negative environmental impacts of the project.
6. Historic Tribal Uses by the People of the Water: There was a historical village, Steh-Chass, on the banks of the Deschutes River estuary. This village was a ceremonial site, a sacred site, where at least five tribes - the Nisqually, Squaxin, Skokomish, Chehalis, and Duwamish gathered for approximately 12,000 years. We would like the current representatives of these tribes to be included in discussions regarding environmental impacts to this area.
7. Historic Building: The Old Brewhouse is listed on both the Washington and National Registers of Historic Places. It truly is a historic structure, but it can be preserved as a point of historic interest without redeveloping it and further adding to the adverse impacts that development has had on Puget Sound rivers and estuaries. #}

   In conclusion, we would like to make the following recommendations:

   1. Include the issues that we have suggested in the scope of the environmental impacts.
   2. Preserve the Old Brewhouse structure for historical purposes but don't redevelop it.
   3. Collaborate with the local tribes to design a display on the site that presents their long history of using this area.
   4. Avoid the adverse impacts of the parking garage and increasing commercial and private vehicle access to the site. #} Thank you for considering our comments. Sincerely,

      Krag Unsoeld, President; Janine Unsoeld, Treasurer; Hildi Flores, Secretary; Ruth Shearer; Doug Canning
      South Puget Environmental Education Clearinghouse (SPEECH) Board Members

      
      

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