September 23, 2011 Environmental Science Associates (ESA) Attn: Erin Higbee-Kollu 550 Kearny St.
, Suite 900 San Francisco, CA 94108 Subject: Scoping Period Comments on the federal National Environmental Policy Act (NEPA) Analysis of the 34th America’s Cup Event and the need to acknowledge and fully address Access Impacts to the Recreational Uses of Windsurfing and Kiteboarding on San Francisco Bay
Dear Ms. Higbee-Kollu: This letter provides scoping comments with respect to development of an Environmental Assessment (EA) used to determine if any of the four federal agencies (NPS, USCG, US ACE and Presidio Trust) will need to prepare either an EIS (Environmental Impact Statement) or construct a FONSI (Finding of No Significant Impact) in order for each of them to establish regulations and conditions under which the 34th America’s Cup (AC34) Event can be authorized, conducted and concluded. The San Francisco Boardsailing Association (SFBA) is a California not-for-profit organization founded in 1986 to protect and enhance boardsailing access, and to promote boardsailing safety and related education in the San Francisco Bay Area. To this end, SFBA actively participates in the planning processes for special events, development, reuse and redevelopment of public and private properties adjacent to San Francisco Bay and the Pacific Ocean which may enhance, threaten and/or directly or indirectly impact the recreational uses of Windsurfing and/or Kiteboarding. SFBA’s main concerns with the AC34 Event (Project) as proposed have to do with the potentially significant impacts to existing launch and on-water access to the Bay. Our comments are provided in the attached comment letter dated August 15, 2011 to the City of San Francisco regarding the significant inadequacy of its CEQA Draft Environmental Impact Report. SFBA’s issues with the DEIR process and its findings focus on the profound denial of the DEIR to acknowledge and evaluate the project-related direct and significant impacts to those existing recreation and fitness activities which take place daily from March through October on San Francisco Bay via access from proposed AC34 venues, including those on federal facilities and federal agencymanaged resources.
Should the Project proceed as described, the World-Class recreational uses of windsurfing and kiteboarding from the Golden Gate Bridge to the San Francisco City-Front will at best be severely restricted and, at worst, be completely prohibited. This will be due to on-water restrictions during AC34 races, and unmanageable traffic congestion and site overuse resulting in adequate access to and/or parking within Crissy Field and Fort Baker (Cavallo Point) during those periods of AC 34 activity in 2012 and 2013. SFBA’s largest disappointment in the DEIR project proposal process lies in its simplification of the CEQA (California Environmental Quality Act) position - taken throughout the document - that only a direct physical impact on a recreational facility (e.g., physical damage or excessive wear-and-tear, etc.) could be a significant impact. In the interest of addressing the existing recreation and fitness activities ignored by the DEIR, SFBA strongly supports the federal agencies AC34 Draft Project Objectives, specifically the following: National Park Service Primary Objectives: • Maintain access for residents, park staff, park partners and visitors. • Provide for diverse, affordable, and enjoyable spectator and visitor experiences consistent with agencies' purposes (joint USCG, NPS objective). • Avoid, minimize or mitigate adverse impacts on parks' resources and values. • Provide for convenient and affordable multi-modal access to parks during the event. • Ensure adequate communications between agencies, Event sponsor and between agency and appropriate public, maritime communities, media, etc. before, during and following the Event (joint USCG, NPS objective). U.S. Coast Guard Primary Objectives: • Avoid, minimize or mitigate impact to the environment, maritime commerce, public use, visitor experience, park partners and recreational uses and access (joint USCG, NPS, USACE objective). • Ensure safety of the Event to include visitors, spectators, staff, park partners, responders and other land and maritime users before, during, and after Event activities (joint USCG, NPS objective). Presidio Trust Primary Objectives: • Minimize disruption to or use of existing park resources. • Respect the needs of park residents, tenants, and visitors. • Maintain access to park facilities and uses. SFBA maintains that the estimated 75,000 visitors to Crissy Field on a peak weekend day in 2012, and 77,000 per peak weekend day in 2013 is an unacceptable overuse of the Crissy Field area, resulting in limited-to-prohibited parking, and traffic congestion that will make the mid-afternoon trip to the Crissy East Beach undoable.
Windsurfing and kiteboarding at Crissy Field and Fort Baker are primarily for advanced boarders, and participants cross all socio and economic boundaries. The sports are equipment intensive - they require access to the shoreline in private vehicles to transport boards, kites, harnesses, pumps, tools, sails, masts and booms… and adequate parking adjacent to surface-friendly, non-pavement space (e.g., grass or grass-crete) at the launch sites to safely assemble gear. SFBA would like to meet with NPS and Presidio Trust EA staff to address needs and constraints, as they address how to best meet the above Project Objectives with regard to launch access and potential parking options. Given the geography and prevailing wind conditions of the Bay Area, the only suitable launch areas are the Crissy Field East Beach, the St. Francis YC Beach, and Fort Baker (difficult launch and for windsurfers only). Given the array of high-tech equipment used, the majority of windsurfers need a minimum of 15 knots of wind to be able to sail… some kiteboarders and formula board sailors can launch with less; this usually occurs between 2:00 PM and 6:00 PM each day of the season. Thus, during AC 34 races, even if existing windsurfers and kiteboarders could reach Crissy Field or the St. Francis YC Beach and find a parking spot in the mid-afternoon when the winds become strong enough to sail, the on-water Race-Area restrictions from 1:00 PM to at least 5:00 PM each day will effectively prohibit anyone from launching while the winds are suitable. SFBA would like to meet with the USCG EA staff to ensure they understand and can best consider our specific needs and constraints during development of their draft “Special Local Regulation” regarding the use of SF Bay during AC34 events. In the interest of meeting the above federal objectives, SFBA would like to meet with federal AC34 Environmental Assessment staff to address how the objectives can best be achieved. SFBA also maintains that the impacts described above are significant, that they should be acknowledged as such and, at a minimum, these impacts need to be avoided, minimized and/or mitigated. We would also like to meet with federal EA staff as they consider the significance of the following Preliminary Impact Topics as listed in the Scoping Announcement: • • • • • • Visitor Experience and Visitor Use (including recreation uses) Visitor Facilities and Amenities (e.g., restroom, water) Traffic and Circulation View sheds / Visual Resources Park Operations (as applies to minimizing access impacts) Recreation (non-motorized watercraft)
In closing, SFBA asks that during development of the AC34 Environmental Assessment, the federal agencies apply their Agency Missions and the viability of their Project Objectives to the consideration of resource and subject area impacts. SFBA maintains that windsurfing, kiteboarding and other recreational uses are fundamental rights and/or privileges, and that disruption of the ability to do so for extended periods of time is a significant impact. SFBA looks forward to working with federal AC34 Environmental Assessment development staff in providing a greater understanding of the constraints and limitations inherent in windsurfing and kiteboarding on San Francisco Bay. We hope to provide you with an appreciation of the significance of the potential impacts, and deeper insight and options into ways in which the impacts can be eliminated, minimized and/or mitigated.
William Robberson, President San Francisco Boardsailing Association BillRobberson@sfba.org
Mr. Michael Savage, NPS Ms. Nancy Hornor, NPS