Concern Over 700 Acre Waterfront Baylands Development

Candlestick Preservation Association

December 2013

Up to 12 million square feet of new commercial, industrial, and residential real estate development is now in the planning and permitting phase on the more than 700 acres of Brisbane Baylands landfill. Plans have been proposed to develop buildings as tall as 160 feet above grade potentially located roughly 500 feet from the edge of the San Francisco Bay along Highway 101. This could put these buildings at a height of possibly 200 feet above sea level given landfill remediation depth requirements of 25 to possibly 50 feet according to the Baylands Draft Environmental Impact Report.

Wall on the Waterfront

There is concern that this development could create a wall of development that would monopolize potentially 7,500 feet of frontage along Highway 101 and the edge of the Bay. Public open space could be largely relegated to patches behind more of the same mixed-use commodity business park structures that litter the waterfront on the Peninsula and surburban areas across the United States.

Recently a proposed high-rise waterfront project was rejected by voters in San Francisco. Citizens feared this same sort of "wall on the waterfront" currently proposed on the Baylands would create a local "Miami Beach" that would do little to improve the community while incurring a great loss of public enjoyment of the valuable Bay resource.

Expanding Urban Bayside Trash Processing

The Baylands plan also includes possibly expanding the Recology waste processing facility from approximately 250,000 square feet to over 1 million square feet. This new facility would potentially handle on-site processing and transfer of waste material such as biomass (compost) and others.

The present Recology facility produces incredible odors that in the high-wind environment are propelled over many square miles of land and water. Numerous complaints have been registered against this facility over many years but the problems continue. From July 1st, 2013 to September 30, 2013, Recology was only fined $300 despite receiving many complaints throughout the period regarding odor emissions.

Other communities where Recology has located and promised to have "impact-free" facilities are realizing that it is very costly and difficult to enforce such requirements. Local communities in urban settings are not equipped with the resources, standards, jurisdiction, or experience for monitoring and enforcement of odor or other airborne pollution. Communities are having a very difficult time dealing with these uses once approved.

Waterfront Preservation Benefits

Successful examples from the Bay Area and around the Country have shown that preserving substantial waterfront space for public use creates an incredible amenity that increases the value of nearby real estate, generates income for business, and is a tremendous benefit for residents, visitors, and new businesses who locate in the community.

Waterfront preservation could be a valuable differentiator for Brisbane to help stem the incredible vacancy rate in office and industrial real estate that places Brisbane far and away at the top of San Mateo County municipalities for percentage of unoccupied commercial space.

The most valuable asset of the Baylands is the waterfront. Placing it behind a wall of buildings or trash processing facilities is not the long-term highest and best use in terms of benefiting public and private interests.

Public Comments on the Baylands Project

Candlestick Preservation Association has prepared public comments for the Baylands Draft Environmental Impact Report and planning processes. Essentially, the comments substantiate the following claims and recommendations:

(1) Establish Waterfront Preservation District:

A minimum Waterfront Preservation District should be established along Highway 101 for the length of the Baylands. It is suggested that this district be at least 900 feet in depth. This is equal to half of the width of the Chicago Lakefront Park System, one of the most successful examples of public and private waterfront cooperation in the world.

The Baylands are fairly regularly shaped with a maximum depth of over 3,500 feet. Such a preservation district would not prevent substantial private development on the Baylands. This preservation district could be set aside initially but developed over many years as funds and plans take shape. However, once this area becomes designated for development, it will be practically impossible to reclaim such a resource.

(2) Cultivate and Embrace Local Recreational Resources:

Local recreational on-land and on-water resources should be cultivated and embraced rather than marginalized and placed in the appendix of consideration for the project. The current impact study claims that despite this potential wall of development mere feet from the water, there would be no impact on the adjacent downwind windsurfing activities. As part of this claim, the impact study does not analyze much of the area that is actually used for windsurfing activities, and it does not apply a meaningful test to determine the true impact on availability of the activity.

The study only considers the relative reduction in wind speed over some arbitrary portions of the adjacent water area, not the absolute levels of post-impact wind over the most important parts of the recreational space. A simple test for minimum acceptable levels of wind speeds and related factors is required for sailing activities such as the America's Cup Regatta, yet no such similar test was determined or applied for the Baylands impact study. Relative reduction in wind speed does not provide enough information about whether the conditions after impact will remain usable.

The Candlestick windsurfing site is one of only three in San Francisco and has been in regular use for 30 years. It is one of the best sites in the Bay Area, having the most regular strong wind by virtue of the Alemany Gap, indifference to tidal effects, unusually flat water due to off-shore winds, freedom from hazards of boat traffic and stranding, and conditions that facilitate beginner-to-expert sailing.

Analysis by Candlestick Preservation Association using on-site wind data records from the past three years show that the relative reduction in wind speed that is proposed by the impact study based on existing realistic sailability requirements would reduce the number of available days of the windsurfing resource at Candlestick Park by up to 40% per year if impacts are unmitigated.

Potential impacts to windsurfing and other unique, valuable, and irreplaceable recreational activities should be recognized and protected to the fullest possible extent through preservation districts, setbacks, reduced heights, surface roughness minimization, building orientation and streamlining, and stepped massing.

(3) Prohibit Potentially Noxious Uses:

In the context of such a sensitive ecological and dense urban environment, highly noxious uses such as trash processing should be avoided. Recology currently operates facilities in the Central Valley, for example, that handle biomass processing efficiently and effectively using minimum energy in open-air settings. The result of these operations is readily used by surrounding farms. Incorporating such processing on the Baylands would require expensive containment as well as higher energy requirements as all operations would have to be enclosed.

Even if fully contained, however, odor, litter, and the health and safety risks associated with processing potentially hazardous materials would likely remain as witnessed by other communities for which similar plans were adopted. Regardless if current operations are expanded or remain at the same levels, Brisbane and San Francisco should adopt a local monitoring and enforcement program that would have specific requirements and associated penalties. Regional agencies such as BAAQMD have demonstrated that they do not have the resources or tools to control these uses to the level that is required in such a fragile setting.

The current noxious users on the Baylands should not be rewarded for years of violating air quality standards. They should be held to account for the promises and public trust that they have violated.

Public Participation

Your participation can make a difference. Public comments on the Baylands Draft Environmental Impact Report are open until January 24th, 2014.

Please see www.keepitwindy.org to learn how you can easily make your voice heard.

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