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Sample Comment 

I’m writing to call on the City of Lakewood to require a full Environmental Impact Statement for the Western State Hospital expansion project. 

While the Western State Hospital Master plan acknowledges some effects on greenhouse gas emissions and air pollution from construction, it fails to acknowledge effects from ongoing operations and maintenance. Clearly this new project intends to create a number of new long-standing facilities. If this is the case, the environmental impact of their continued use must be accounted for.

There are numerous gaps in the environmental analysis that was undertaken in the SEPA Checklist process, which would be remedied by a full EIS. These gaps include:

• The failure to adequately address greenhouse gas emissions from the project, including no mention of the GHG impact from facility operations. This is highly problematic, given that the expansion includes at least three new buildings for the forensic hospital, residential treatment facility, and the residential cottage; demolition of at least 520,000 square feet of building space, which can also result in GHG emissions; and the addition of 334 new parking spaces, which contradicts the Checklist’s claim that emissions from vehicles “will be negligible” since no modeling has been done to demonstrate the GHG impact of these parking spaces.

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• The increased use of natural gas to power hospital operations, without accounting for the GHG and air pollution impact from gas combustion. The Checklist claims that GHG emissions will not increase, yet the Master Plan states that “based on the master plan building area growth projections, it is expected the natural gas demand may increase by 30% for the campus as a whole”. An increase in natural gas use without any significant energy efficiency upgrades or carbon sequestration plans can only result in an increase in GHG emissions.

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• The failure to plan for compliance with the 2019 Washington Clean Buildings Act, which requires existing buildings over 50,000 square feet to reduce energy use by 15% from 2009-2018 averages, as well as to comply with Governor Inslee’s Executive Order 18-01, which requires that state-owned facilities undergoing new construction or major renovation facilities be developed as net-zero capable, and that renewable energy sources to achieve net zero should be developed when feasible. The plan fails to include renewable energy generation on site, without proving that this would be unfeasible, as required.

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• The protocols for identification of Endangered or Threatened Species of Plants specifies that multiple field visits over a series of several years are required to identify the presence of any such plants. The Master Plan states that individual projects in the future will account for this, but this is vague and creates no guarantee. These comprehensive field studies should be completed prior to design moving forward.

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• The failure to adequately account for the environmental impact of the Master Plan for Western State Hospital serves not only to harm the environment, but to push through the expansion of a behavioral health facility known to traumatize its patients – a facility that takes people from the community when all empirical evidence shows that access to community and freedom is necessary for mental health.

For more detailed comments on the gaps in the existing SEPA Checklist, please see this document that outlines No New Washington Prisons Comments on SEPA Checklist for 2021 Revised Western State Hospital Master Plan found here: https://www.nonewwaprisons.com/_files/ugd/49d533_98ac3cb1ed5b4a488d19dc9e82e040e8.pdf 

The City of Lakewood must conduct a full environmental impact statement to adequately analyze the impacts of the expansion project and determine appropriate mitigation efforts. Please reverse the determination of nonsignificance and conduct a full EIS.