Copy of Letter to Burlingame re. Coyote Point

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Date: Thu Apr 22 1999 - 14:28:22 PDT

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From: Eyes4Hire@aol.com-DeleteThis
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Date: Thu, 22 Apr 1999 17:28:22 EDT
Subject: Copy of Letter to Burlingame re. Coyote Point
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Meg Monroe, City Planner April 20, 1999
City of Burlingame
501 Primrose Road
Burlingame, CA 94010

Planning Commission
City of Burlingame
501 Primrose Road
Burlingame, CA 94010

Re. Proposed Development at 301 Airport Boulevard
Response to Comments Document & 4/26/99 Hearing Date

Dear Ms. Monroe and Commissioners,

I am writing to request that the Planning Commission extend the hearing date
for commentary on the Response to Documents (Response) prepared by ESA as it
regards impacts to windsurfing. The primary reasons for requesting an
extension are:

1) The Response is 279 pages long and makes technical arguments which
require careful reading and evaluation by experts on such topics as
meterology and aerodynamics. It is unlikely that a comprehensive and complete
evaluation of the Response can be made in the short time allotted.

2) The windsurfing community has been delayed in receiving or reviewing
a copy of the Response due to problems contacting City Hall and procedures at
the Burlingame Library.

A clear and comprehensive response by the windsurfing community is especially
critical to a fair finding of sufficiency given the fact that the Response
appears to have discounted almost all comments by windsurfers with regard to
determination and definition of significant impact to windsurfing. I expect
that an extension of approximately two weeks would allow the windsurfing
community to evaluate the Response and make clear and intelligent commentary.

Access to the Response

The Response was delivered to the City of Burlingame by the consultant, ESA,
on 4/15/99 and the city published public notice on 4/16/99. On 4/16/99,
myself and George Haye, also of the SFBA, repeatedly called the Burlingame
Planning Department in an effort to determine if we could pick up a copy of
the Response. Unfortunately all of the phones at City Hall were disabled
during most of the day on 4/16/99 and as well as much of the day on 4/19/99.
The caller heard a ringing phone going unanswered. The fact that phones were
not being answered at City Hall led to a reasonable conclusion that City Hall
was closed for one reason or another.

I called the Burlingame Public library on 4/19/99 and was informed by Brenda
at the reference desk that they had copies of the Response, but that they
were not yet placed for public viewing. She could not advise me as to the
page count on the response because it was in another area of the library. I
explained that I was trying to get access so that I could pass the
information from the Response to the broader windsurfing community. At that
point Brenda did indicate that she could get me special access if I could not
get through to City Hall. She was also kind enough to advise me that City
Hall was open but that the phone lines had been cut.

Evaluation of the Response

The size of the Response, 279 pages, makes distribution of copies difficult
and expensive. We are currently working on having key sections distributed
via the internet. The Master Response, located at pages 107-114 of the
Response, and other portions of the Response are rather technical and require
review of someone expert at meteorology and/or aerodynamics. All of the
experts we have access to are unpaid volunteers who may have difficulty
responding on such short notice due to work and family obligations.

Retained Definition of Significant Impact

The consultant has made the decision to retain the proposed standard for
significance established in the 12/26/98 technical memorandum. That standard
does not take into account factors that the windsurfing community insisted
were critical, such as turbulence. This standard considers changes in wind
velocity but does not consider turbulence at all. The windsurfing community,
those who have actually windsurfed and experienced the impacts of both
changing wind velocity and turbulence, strongly expressed in commentary that
turbulence factors are as important or more important than velocity changes.

There are no better experts as to what constitutes a serious impact to
windsurfing than members of the windsurfing community. While there are no
experts who have studied what percentage change in velocity or turbulence
intensity might be significant, members of the windsurfing community
definitely do know what factors must be considered in a definition, and
turbulence is one of these factors as expressed in a number of comment
letters. I have not had time to fully review the Response, but it appears the
consultant may have too easily dismissed the public comment by the members of
the windsurfing community given that there is no consideration of turbulence
in the definition of significant impact and there were no revisions to the
Recirculated Draft EIR (page 56-57 of the Response) with regard to
windsurfing in the face extensive and carefully considered commentary ( other
than correcting one mislabeled diagram).

The lack of change is especially surprising in light of a March meeting
between members of the SFBA and the consultant, city planner, and developer.
The consultant spent at least two hours gathering information verbally as to
the mechanics of windsurfing and the uses of windsurfing uses of Coyote
Point. Clear descriptions of how turbulence impacts windsurfing were
communicated and the consultant gave the impression that such impacts would
be considered. There are points in the Response where it seems to be implied
that the windsurfing community failed in not creating a alternative standard
for significant impact. What the windsurfing community did do is provide the
consultant with the information needed to possibly develop an adequate
standard. The consultant failed to use the information provided to develop a
standard for significant impact that relates to the realities of windsurfing.

Significant New Data not Subjected to Public Review

On March 8, 1998, I wrote and delivered a letter to the Burlingame Planning
Department (see Response page 235-244) regarding turbulence intensity data
which was received from ESA om 3/7/99 (less than 24 hours prior to the close
of comments on the RDEIR). This turbulence intensity data should have been
carefully considered with regard to impacts on windsurfing and subjected to
public review. The diagrams showing increases in turbulence intensity seem to
show that an extensive portion of the study area will be greatly impacted
(please refer to the letter).

The response by ESA (see Response page 245-246) included the following:

"Because there is a correlation between the values of R and TI, use of the
R-value plots alone appears to be a more sensitive tool for distinguishing
changes in wind condition and thus appears to provide a reasonable basis for
evaluating the wind effects on the project."

This analysis fails to recognize that reduced wind velocity (lower R-value)
and increased turbulence (increase in TI) BOTH have negative impacts on
windsurfing and the impacts of one is additional to or compounds the impacts
of the other. Windsurfing underpowered in lighter winds is difficult (like
riding a bike at very slow speed with your feet locked into the pedals).
Windsurfing in lighter winds while the wind speed is ranging up and down
across a greater range is even harder as one is having to make great
adjustments while generally off balance already.

Thank you for your consideration of the incorporated request and information.
Please feel free to call me with any questions or information.

Sincerely,

Peter Thorner
Chair, Coyote Point Committee
San Francisco Boardsailing Association

(415) 454-3522 work
(510) 547-4422 home
(510) 805-1830 pager

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