Coyote Point Update

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Date: Wed Mar 17 1999 - 20:01:38 PST


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Date: Wed, 17 Mar 1999 23:01:38 EST
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Subject: Coyote Point Update
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Sorry this update is a bit tardy. I am still catching up at work after a
marathon effort to complete and submit the SFBA response to the draft
environmental impact report (DEIR) regarding the proposed development to be
located upwind from Coyote Point. A 24-page response by the SFBA was submitted
to the City of Burlingame on March 8th. The response compiled the comments
received from members and from the windsurfing community at large. The cover
letter and index portion of the response is appended at the end of this
update. The response expressed concerns regarding the technique used in
evaluating whether or not there would be a significant impact to windsurfing
and also stressed the importance of Coyote Point as a resource for
windsurfing.

The SFBA response, along with other letters from the public, will be forwarded
to the consultants who are responsible for the contents of the environmental
impact report (EIR). It will be up to them to evaluate our concerns and
address them. When they release the next revision of the EIR, it will be up to
the windsurfing community to evaluate it and then let the Planning Commission
know if there are any inaccuracies or concerns that were not dealt with. It
will likely be a few weeks before the EIR is re-released.

To date the SFBA and windsurfing community appears to have had a significant
impact on the planning process. Prior to the public meeting and comments by
windsurfers, the general opinion of the city planner and environmental
consultants seemed to be that the DEIR had sufficiently dealt with wind
issues. After receiving input at the public meeting, by letter, and through
direct meeting with the SFBA, it appears that the environmental consultant
will seriously reconsider the wind issues. The consultant has already
forwarded us new wind tunnel data on turbulence that seems to support our
contention that impacts from turbulence may be significant. It remains to be
seen how the consultant will interpret this data and relate it to impacts on
windsurfing.

After the February 22nd Planning Commission meeting, which was attended by
approximately 60 windsurfers, the SFBA was invited to meet with the city
planner, the environmental consultants and the developer. A group from SFBA
attended the meeting on March 3rd. The meeting was primarily Q&A by the
consultants who were interested in learning more about how windsurfers use the
Coyote Point area. We had the opportunity to describe in detail how
windsurfers use the area and we were also able to give a primer on the
mechanics of windsurfing. The information on how windsurfing works helped the
consultants to understand how windsurfers are impacted by gusty winds,
turbulence, holes and the like. The developer and city planner were interested
and involved throughout the meeting and asked a number of intelligent
questions as well.

Thank you to everyone who has taken the time to participate in this effort..

Peter

    - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
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Meg Monroe, City Planner March 6, 1999
City of Burlingame
501 Primrose Road
Burlingame, CA 94010

Dear Ms. Monroe,

This document outlines SFBA's concerns regarding the office development
project proposed for 301 Airport Boulevard in Burlingame. These are a
compilation of the concerns of the 1,600 members of the San Francisco
Boardsailing Association (SFBA) and apply primarily to the wind information in
the Recirculated Draft Environmental Impact Report (RDEIR). The SFBA is a non-
profit organization staffed 100% by volunteers. The SFBA was founded in 1986
to address the concerns of the boardsailing/windsurfing community in the San
Francisco Bay Area. Our main goals include promoting safety, providing
education, ensuring access and improving facilities. We serve the windsurfing
community by working with local governments to maintain access at key sailing
spots throughout the Bay Area, by working with the Coast Guard to refine
safety procedures, by sponsoring races and special events for our members, and
by publishing a newsletter alerting our members to upcoming events, safety
issues and access issues.

The SFBA formed the Coyote Point Committee to solicit comments from the
windsurfing community and to investigate the completeness and accuracy of the
RDEIR. Members of the Coyote Point Committee have contacted hundreds of SFBA
members as well as other members of the windsurfing community to get feedback
regarding the proposed project. The combined input from these windsurfers
alerted the SFBA to significant flaws in the RDEIR with regard to completeness
and accuracy. The primary conclusions reached are as follows:

· The standard for significant impact, as proposed in the Wind Analysis
Technical Report is insufficient. The standard accounts for changes only in
average wind velocity. Examining only these changes in velocity will not
reveal whether or not windsurfing will be significantly impacted. While
windsurfing is seriously impacted by reductions in overall wind velocity,
increases in wind range (gustiness), severe turbulence, and vortex generation
also impact windsurfing conditions.

· The wind tunnel tests, which were the basis for the conclusions reached in
the RDEIR, fail to account for important factors. The wind tunnel study did
not examine increases in wind range (gustiness), severe turbulence, and vortex
generation that will impact windsurfing. The wind tunnel study also does not
account for thermal gradients which are normally present in the development
area and which may have a significant impact on how far downwind destabilizing
effects on the wind may be felt. The wind tunnel methodology also has very
limited capabilities when it comes to describing wind behavior near the
surface of the water which is the only place that wind impacts are significant
to windsurfing.
  
· The real world experience of windsurfers points to impacts far more serious
than those suggested by the wind-tunnel study and the RDEIR. Many windsurfers
have reported noticeably significant impacts, including highly disturbed
airflow, as far as ½ mile to 1 mile downwind from buildings in the 100' height
range.

· Coyote Point Park is an irreplaceable resource for windsurfing in the San
Francisco Bay Area. The park offers excellent conditions for all levels of
windsurfers and has a greater parking and launching capacity than all other
San Mateo County bayside windsurfing sites combined.

· The alternative development proposals outlined in the Draft Environmental
Impact Report (DEIR) fail to meet CEQA requirements for a reasonable range of
alternative proposals. The alternative development plans leave in place all of
the proposed structures that are most likely to have a negative impact on
windsurfing. No alternatives with lesser impacts are proposed.

· If the impact of the project upon windsurfing cannot be convincingly
assessed, then any planning decision made needs to err in favor of protecting
the existing windsurfing use. This is especially true in light of BCDC
guidelines. The BCDC guidelines established for the area of the development
require that a project should be designed to encourage the use of the adjacent
public-access areas by the public. A development that has any negative impacts
on windsurfing would not only fail to meet the BCDC guidelines, it would be in
direct contravention to those guidelines.

· Since impacts to windsurfing are underestimated, no mitigation is examined
in the RDEIR. However, Coyote Point Park is an irreplaceable resource for
windsurfing in the San Francisco Bay Area. The park offers excellent
conditions for all levels of windsurfers and has a greater parking and
launching capacity than all other San Mateo County bayside windsurfing sites
combined. The park is the only launch site in the Bay Area with amenities
such as restrooms, showers, a snack bar, grass rigging areas and a full
service shop and rental facility within walking distance. It is unlikely that
another site could be established as mitigation for the loss of Coyote Point.

The conclusions listed above are in summary form. Please refer to the attached
appendices for more detailed information and additional points regarding these
conclusions.

In the judgment of the SFBA, the RDEIR and incorporated Technical Report are
inaccurate and incomplete since the reports conclude that there is no
significant impact to windsurfing from the proposed project. In light of the
points raised above, we feel further efforts to quantify the impacts to
windsurfing should be made. It is likely that the impacts to windsurfing will
be hard to quantify and understand through modeling and wind tunnel testing,
especially for anyone who is not familiar with the mechanics of windsurfing.
The SFBA and its members are willing and ready to participate in the planning
process and to share their knowledge of windsurfing so as to improve the
process.

In addition to the wind impacts, many members of the SFBA have noted that the
proposed project exceeds the height limit and the lot coverage limit
established by the City of Burlingame design guidelines for the project area.
The SFBA strongly opposes approval of a variance that would allow construction
of any project that exceeds established design guidelines. The SFBA is also
concerned with project impact to views from Coyote Point Park and to traffic
in the Coyote Point area.

While the SFBA response deals primarily with wind impacts, we have also heard
many comments by members of the windsurfing community who are concerned about
traffic impacts. Many windsurfers reach Coyote Point Park by coming eastbound
on Airport Boulevard. Others regularly stop at the ASD windsurfing shop prior
to windsurfing and then return to the park on eastbound Airport Boulevard.
Trip generation estimates in the DEIR and RDEIR may fail to account for
windsurfing traffic which is generally seasonal and which may not occur even
in season during periods of low wind.

We have heard many comments by members of the windsurfing community who are
concerned about traffic impacts. Many windsurfers reach Coyote Point Park by
coming eastbound on Airport Boulevard. Others regularly stop at the ASD
windsurfing shop prior to windsurfing and then return to the park on eastbound
Airport Boulevard. Most of the windsurfers leave Coyote Point to go south on
101 via the overpass at Popular Avenue and the southbound ramp at North
Amuhlett road. The RDEIR indicates that the existing Level of Service for
southbound traffic to 101 is F - which is extremely poor. In addition to
further impacts to this intersection, we anticipate that since the limited
access from the proposed development to southbound 101 is confusing, the
adjacent residential area will experience significant additional traffic.
Furthermore, trip generation estimates in the DEIR and RDEIR, which are
limited to peak commute traffic, may fail to account for windsurfing traffic
which is generally seasonal and which may not occur even on some days in
season during periods of low wind. The proposed project has significant and
unmitigated impacts to wind, views and traffic, which are not fully documented
in the RDEIR. In light of these failings, we strongly oppose finalization of
the RDEIR by the City of Burlingame.

Sincerely,

Peter Thorner
Chair, Coyote Point Committee

Cc: William Robberson
President, SFBA

 

APPENDICES

A. DEFINITION OF SIGNIFICANT IMPACT 5

B. WIND TUNNEL TEST METHODOLOGY 8

C. REAL WORLD CASES 10

D. COYOTE POINT AS A WINDSURFING RESOURCE 11

E. BAY CONSERVATION & DEVELOPMENT COMMISSION 13

F. ALTERNATIVES REQUIRED UNDER THE CALIFORNIA 14
        ENVIRONMENTAL QUALITY ACT

G. DIAGRAM SHOWING PRIMARY SAILING AREAS 15

H. LETTER FROM MIKE GODSEY REGARDING WIND 17
        TUNNEL STUDY

I. LETTER FROM BUCK LYONS REGARDING WIND 19
        SHADOW EXPERIENCE IN ARUBA

J. E-MAIL FROM GLENN TAYLOR REGARDING WIND 21
        SHADOW EXPERINCE AT REDWOOD SHORES

K. LETTER FROM GREG HARRIS REGARDING WIND 22
        DATA COLLECTED AT SFO

 



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