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-nasa
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/9789812701602_0069.pdf
) 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!CELEXnumdoc&lg=EN&numdoc=31999L0077&model=guichett
and at
http://eur-lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=EN&numdoc=32003L0018&model=guichett
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