Hi all, Here's what I both emailed and hand delivered to Planning and Redevelopment yesterday on the Draft Environmental Impact Report for the toxic, gentrifying, Hunters Point Shipyard Phase II Development (which is set to be built by environmentally criminal Lennar Corporation). 1/12/2010 Public Comments On: - CITY AND COUNTY OF SAN FRANCISCO PLANNING DEPARTMENT File No. 2007.0946E - SAN FRANCISCO REDEVELOPMENT AGENCY File No. ER06.05.07 - State Clearinghouse No. 2007082168 Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project (formerly the "Bayview Waterfront Project") Draft Environmental Impact Report TO: Bill Wycko Environmental Review Officer San Francisco Planning Department 1650 Mission Street, Suite 400, San Francisco, CA 94103 and Stanley Muraoka Environmental Review Officer San Francisco Redevelopment Agency One South Van Ness Avenue, Fifth Floor, San Francisco, CA 94103 FROM: Eric Brooks Sustainability Chair, San Francisco Green Party 288 Onondaga Ave # 4 San Francisco, CA 94112 brookse@igc.org 415-756-8844 Environmental Review Officers, I am submitting these comments to point out, and insist upon correction of, serious inadequacies, in the the Draft Environmental Impact Report (DEIR) for the Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project, and in the project plans to which the DEIR refers. I will focus my comments in two categories - 1) SERIOUS INADEQUACIES IN ADDRESSING, AND FAILURES TO ACCOUNT FOR, PROJECTED SEA LEVEL RISE 2) FAILURE TO ACCOUNT FOR AND AVOID HEALTH AND ENVIRONMENTAL HAZARDS OF TOXIC MATERIALS, INCLUDING BUT NOT LIMITED TO CHRYSOTILE ASBESTOS AND IONIZING RADIATION; AND, FAILURE TO MEET THE LEGAL PRECAUTIONARY PRINCIPLE ESTABLISHED BY ORDINANCE IN THE SAN FRANCISCO, CALIFORNIA, ENVIRONMENT CODE CHAPTER 1: - PRECAUTIONARY PRINCIPLE POLICY STATEMENT - SECTIONS 100-104 (see http://library.municode.com/HTML/14134/level1/C1.html ) Comments: 1) SERIOUS INADEQUACIES IN ADDRESSING, AND FAILURES TO ACCOUNT FOR, PROJECTED SEA LEVEL RISE As is now commonly understood and established by widespread and overwhelming scientific consensus, the Earth's oceans and the San Francisco Bay are now undergoing sea level rise due to planetary climate warming. Until very recently, science policy groups, including and especially the Intergovernmental Panel on Climate Change (IPCC) had been projecting that the worst case scenario for global sea level rise would be no higher than 1.5 meters by the year 2100. However new data and reports released in November 2009 now indicate that the worst case scenario for global sea level rise is now projected to be at least 2 meters by the year 2100. More importantly, NASA's James Hansen, widely recognized as the preeminent climate change expert on Earth, argued credibly as early as 2007 that worst case scenario sea level rise will instead be 5 meters by the year 2100. In light of the fact that the IPCC's predictions of sea level rise from just two years ago have been found to be inadequate by an entire one half meter, and that James Hansen had previously argued in 2007 that the IPCC's projections were indeed inadequate, Hansen's projection of a worst case scenario of 5 meters sea level rise by the year 2100, must now be assumed as the guide for all plans for the Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project. The following data and reports prove this case: - On Nov 22, 2009 NASA released new satellite gravimetric data from a 7 year study of Antarctica showing that the massive East Antarctic Ice Sheet, which scientists previously thought was gaining in volume, is suddenly (as of 2006) undergoing rapid and widespread melting. See http://www.guardian.co.uk/environment/2009/nov/22/east-antarctic-ice-sheet-n... The NASA study report itself can be ordered from Nature Geoscience at http://www.nature.com/ngeo/journal/v2/n12/full/ngeo694.html This research also shows massive new and more rapid melting in West Antarctica and Greenland. - As of November 24, 2009, in a report entitled 'The Copenhagen Diagnosis', even historically overly equivocal IPCC scientists revised their sea level rise projections to a possible 2 meters (6.5 feet) by the year 2100. See the Reuters news release on the report at http://www.reuters.com/article/idUSTRE5AN4L620091124 and the actual report itself at http://www.copenhagendiagnosis.org/download/default.html The portion of this report which describes new sea level rise projections begins on page 37 of the report. - In a March 2007 report, NASA's James Hansen, who first alerted the general public and policy makers to the global climate crisis, discusses the probability of a 5 meter (16.25 feet) sea level rise. See Hansen's report at: http://www.iop.org/EJ/article/1748-9326/2/2/024002/erl7_2_024002.html Note that Hansen's report is speculative by nature, simply because ice sheet melting and other data will not exist to prove the case that he argues, until that level of melting is already happening. However, given that the NASA gravimetric data noted above shows that Antarctic and Greenland ice sheets are currently undergoing rapidly accelerating melting at previously unforeseen rates (and at rates which continue to accelerate even further) there is absolutely no reason whatsoever to doubt Hansen's predictions; especially in light of the fact that Hansen's past predictions have consistently proved to be correct. CONCLUSIONS - SEA RISE: Hence, since James Hansen's prediction of a worst case 5 meter sea level rise by the year 2100 is highly credible, it is, at the very least, that standard of a predicted 5 meter rise which must be used as the guideline for all plans for the Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project. More importantly, good engineering practice (especially when dealing with a factor with such high unpredictability and potentially severe and costly outcomes as climate induced sea level rise) would call for at least an additional 100% margin of safety over worst case projections to be adopted for the Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project. This means that the standard for assumed sea level rise in the project should be at least 10 meters (32.5 feet) of sea level rise by the year 2100. Even if planners were to use the likely far too equivocal 2 meter worst case sea rise projection in The Copenhagen Diagnosis, an additional 100% margin of safety would still demand a minimum 4 meter rise assumption. Since the project plans and DEIR for the Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project could not have envisioned the November 2009 reports noted above, and since planners and drafters were apparently unaware of Hansen's earlier and even more serious 5 meter rise projection, the project plans and DEIR are therefore utterly inadequate in addressing and including sufficiently high sea level rise projections. Specific Inadequacies Numerous And Widespread - In Addition Most DEIR Sections Have No Sea Rise Analysis At All, And Must Now Include Such Analysis The sections of the DEIR which deal most comprehensively with sea level rise; Volume 2 Section II. Project Description; and Volume 2 Section III.M. Hydrology and Water Quality; have numerous entries on sea level rise. In nearly every instance, the core predictions and plans referenced in the DEIR are dramatically overwhelmed by even the new -minimum- worst case scenario described above of 2 meters (78 inches) sea level rise. Most of the DEIR and project plan sections mentioning sea level rise assume a maximum of 36 inches sea level rise. Most notably, even where a potential 55 inch rise is mentioned as theoretically possible, that potential is downplayed with the following statement which, in light of the new information shown above, can now be seen to be completely and dangerously incorrect; "Even among projections considered plausible, albeit high, by the CALFED Independent Science Board, a SLR of 36-inches would not occur until about 2075 to 2080 and by about 2100 the SLR could reach 55 inches. However, sea level observations since the publication date of the ice cap melt studies, although not conclusive to establish a new trend in SLR, do not show the accelerated SLR trajectory predicted by some of the reports." Clearly, new observations do -indeed- show such accelerated sea level rise. Other sections of the DEIR which specifically mention sea level rise and which need to be carefully and extensively revised to account for both the new data and Hansen's report are: Volume 2 Sections III.K and III.L and Volume 3 Sections III.N and III.S, Section IV. and Section VI. Furthermore, almost every -other- section of the DEIR and the project plan referenced, is impacted by sea level rise; and in light of the much higher 2 to 5 meter sea level rise projections now shown to be warranted, nearly the entire DEIR and the project plan that it references must be carefully reexamined and revised to account for sea level rise impacts. To get a sense of why such an overarching reexamination of nearly the entire DEIR is necessary, see the following online interactive sea level rise projection maps: The Project Area At 2 Meters Sea Level Rise: http://flood.firetree.net/?ll=37.7293,-122.3995&z=3&m=2 The Project Area At 5 Meters Sea Level Rise: http://flood.firetree.net/?ll=37.7293,-122.3995&z=3&m=5 Even at the minimum 2 meter rise worst case assumption, the sea inundations into the project area clearly and profoundly impact the entire project in fundamental ways that are not adequately addressed in the DEIR and the referenced project plan. And the 5 meter projection map is undeniably astounding in its implications. Therefore the following sections; III.A. Intro to Analysis; III.B. Land Use; III.C. Pop., Housing, & Employment; III. D. Transportation; III. E. Aesthetics; III.H. Air Quality; III.J. Cultural and Paleontological Resources; III.O. Public Services; III.P. Recreation; III.Q. Utilities; III.R. Energy; and V. Other CEQA Considerations; all of which shockingly contain no significant references to sea level rise whatsoever, must now all be carefully reviewed and revised to account comprehensively for the far reaching impacts of the sea level rise projections indicated above. Furthermore, all of the DEIR Appendices must likewise be assessed as to their accuracy in regard to sea level rise. Most notably, Appendices L, S, and V-2 each reference sea level rise, largely mirror the same serious shortcomings and errors shown in the DEIR, and must therefore be strongly questioned. And as in the case of the overall DEIR itself, all of the other Appendices are also affected and should be reexamined in relation to the new data and reports as to their adequacy. Particularly important in this respect is Appendix N-2 which discusses Yosemite Slough with almost no mention of sea level at all; this when sea level rise will clearly have profound impacts on plans for the Slough. Sea Level Rise Interactions With Liquefaction & Hazardous Materials The most important inadequacies of the DEIR and project plan lie in their failure to account adequately for the potential of sea level rise to severely exacerbate both liquefaction and the leaching and harmful interactions of hazardous materials in the project area. Liquefaction In the report entitled 'Vulnerability assessment to liquefaction hazard induced by rising sea-levels due to global warming' (see http://www.thefreelibrary.com/_/print/PrintArticle.aspx?id=155784183 - or purchase the full article with graphics at http://eproceedings.worldscinet.com/9789812701602/preserved-docs/97898127016... ) the report authors establish clearly that liquefaction dangers increase as sea levels rise, and increase rapidly after sea level rise exceeds 1 meter. Shockingly, neither the DEIR section III.L. Geotechnical; nor section III.M. Hydrology and Water Quality; mention in any substantial way the dangers of potential interactions between sea level rise and liquefaction. It is absolutely imperative that the DEIR and the project plan, outline a detailed analysis of these potentially extremely hazardous interactions, and outline plans for how they would be prevented; all with the full range of 2 to 5 meters sea level rise assumed. Hazardous Materials By far the most troubling aspect of the DEIR and project plan's neglect of sea level rise assessments is in their failure to sufficiently address potential sea level rise interaction with hazardous materials in and on the project site. In 'Implications of Sea Level Rise for Hazardous Waste Sites in Coastal Floodplains' (see http://www.epa.gov/climatechange/effects/downloads/Challenge_chapter9.pdf ) the authors establish clearly the extensive dangerous interactions that can occur as sea level rise exacerbates flooding and triggers other negative impacts in hazardous waste sites, such as those in the Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project. Yet astoundingly, neither the DEIR section III.K. Hazards and Hazardous Materials; III.L. Geotechnical; nor section III.M. Hydrology and Water Quality; assess in any comprehensive or substantial way the very serious dangers of potential interactions between sea level rise and the numerous hazardous materials and residues in the project plan area. It is crucial that comprehensive detailed assessments of such potential interactions be included in the DEIR and project plan; assessments which assume the full spectrum of 2 to 5 meters sea level rise projected above. However, regardless of the findings of such new assessments, the dramatic sea level rise scenarios projected above could so overwhelm the project area that unforeseen and unavoidable extremely dangerous leaching, flushing, mixing, out-gassing and dispersion of a veritable toxic soup of hazardous materials could take place in the project area. It is therefore imperative that all hazardous materials be completely removed from the entire project area before any development is permitted to proceed. Under a scenario of sea level rise between 2 and 5 meters, no capping or other on-site containment of any hazardous wastes can be adequate to assure the prevention of unacceptably dangerous leaching, flushing, mixing, out-gassing and dispersion of hazardous materials; all which in turn would lead to the inevitable poisoning of the environment, animals, and people, living in, working in, and visiting the area. These remarks on sea level rise disrupted hazardous materials now segue well into the second and final category of my comments. 2) FAILURE TO ACCOUNT FOR AND AVOID HEALTH AND ENVIRONMENTAL HAZARDS OF TOXIC MATERIALS, INCLUDING BUT NOT LIMITED TO CHRYSOTILE ASBESTOS AND IONIZING RADIATION; AND, FAILURE TO MEET THE LEGAL PRECAUTIONARY PRINCIPLE ESTABLISHED BY ORDINANCE IN THE SAN FRANCISCO, CALIFORNIA, ENVIRONMENT CODE CHAPTER 1: - PRECAUTIONARY PRINCIPLE POLICY STATEMENT - SECTIONS 100-104 (see http://library.municode.com/HTML/14134/level1/C1.html ) Chrysotile Asbestos Two recent European Union (EU) directives can be viewed at http://eur-lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnu... and at http://eur-lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnu... In those directives, the EU establishes that "No threshold level of exposure has yet been identified below which chrysotile asbestos does not pose carcinogenic risks;". In those directives, the EU also bans all applications and uses of chrysotile asbestos as of the year 2005. Chrysotile or 'white' asbestos is the same type existing naturally in serpentine rock at the Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project area and in other development areas in the Bayview Hunters Point. Previous grading and other development activities in those other development areas has resulted in chrysotile dust contamination on the Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project area. Because it has been established that there is no safe level of exposure to chrysotile asbestos, all asbestos dust which has arisen from other construction sites must be completely removed from the Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project area before any any development can begin in the area. Further, because it has been established that there is no safe level of exposure to chrysotile asbestos, no grading whatsoever of any asbestos laden serpentine rock can be allowed in the Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project area. Such grading presents unnecessary and unacceptable risks to human health. All plans of the Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project which permit the grading of asbestos laden serpentine rock must be nullified, and alternative plans which will not disturb chrysotile asbestos must be adopted. Ionizing Radiation In June 2005 the National Academies of Science reported that there is no safe dose of ionizing radiation (see http://www8.nationalacademies.org/onpinews/newsitem.aspx?RecordID=11340 ) Therefore no development can be allowed to proceed in the Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project area until all radiological waste materials are completely removed from the area. Proceeding with any development while such wastes remain anywhere in the project area, presents unnecessary and unacceptable risks to human health. The Precautionary Principle And All Hazardous Materials Furthermore, because San Francisco's own legally established Precautionary Principle also requires that no person be unnecessarily exposed to chrysotile asbestos, ionizing radiation, or any other hazardous materials, it is doubly mandated that all asbestos laden serpentine rock must be left completely undisturbed, and all radiological and other hazardous materials must be completely removed from the Candlestick Point-Hunters Point Shipyard Phase II Development Plan Project area before any development can proceed. -end of comments- Eric Brooks Sustainability Chair, San Francisco Green Party 288 Onondaga Ave # 4 San Francisco, CA 94112 brookse@igc.org 415-756-8844