County of San Mateo
455 County Center, 2nd Floor
Redwood City, CA 94063
Re: Draft Environmental Impact Report for Big Wave Wellness Center and Office Park
Dear Ms. Leung:
Please find attached our comments regarding the proposed Big Wave Wellness Center and Office Park. We are both water quality specialists at the San Francisco Estuary Institute. However, the views expressed in this letter are our personal opinions and do not represent the position of SFEI. As citizens of Moss Beach and the Coastside, we are submitting our technical concerns about the Draft Environmental Impact Report (DEIR) circulated by San Mateo County.
Jay Davis, Ph.D., Senior Scientist, San Francisco Estuary Institute
Nicole David, Environmental Scientist, San Francisco Estuary Institute
Jay Davis and Nicole David
Moss Beach, CA
Comments from Nicole David and Jay Davis on the Big Wave Draft EIR
While we applaud the Big Wave team’s goal of promoting the well-being of the developmentally disabled, placing this project in the proposed location would be unwise due to unacceptable impacts on Fitzgerald Marine Reserve and unacceptable risks faced by the residents and owners of the proposed development. The land proposed for development should be receiving consideration as a valuable addition to the open space on Pillar Point Bluff and the Half Moon Bay Terrace, rather than a site for the region’s largest office complex.
The Marine Reserve (including Pillar Point Marsh) is an exceptionally valuable ecosystem that deserves the maximum amount of protection that can be provided.
The residents and owners of the proposed development would also face a risk of flooding that is significant, that would increase over time due to sea level rise, and that is understated in the EIR.
Other factors making this an inadvisable location for the proposed development are the presence of an earthquake fault 500 feet from the property, and the presence of a significant tribal archaeological site on the property.
Major concerns also exist relating to the lack of infrastructure to support this community, and the associated impacts on traffic and concerns related to the capacity of the sewage collection and treatment system to accommodate flows during emergency situations.
Our comments, however, focus on 1) the impacts of the proposed project on the Marine Reserve and 2) on the flooding risks that were understated in the EIR.
A. Building the largest mixed-use development ever proposed on the Coastside immediately adjacent to Fitzgerald Marine Reserve would constitute an unacceptable degree of risk and impact for an extremely valuable and already threatened ecosystem.
1. The Reserve is an extremely valuable ecosystem.
o The Reserve supports extensive wildlife use, including a major seal haul-out close to the property on the west side of the bluff.
o The Reserve includes most extensive and diverse tidepools in the County that are already suffering from excessive human use.
o The Reserve is designated as an Area of Special Biological Significance and therefore receives special protection under the California Ocean Plan. Since 1983, the Ocean Plan has prohibited the discharge of both point and nonpoint source waste to ASBS, unless the State Water Board grants an exception. Exceptions can be granted if special protections are followed. The special protections require maintenance of natural water quality and monitoring to demonstrate this.
o The Fitzgerald Reserve is considered one of the most threatened ASBS http://www.cacoastkeeper.org/document/aquagems-report.pdf
o Pillar Point Marsh, which is part of the Reserve and directly adjacent to the proposed development, is a rare, ancient, and productive ecosystem that has been present at the site for at least 150 years.
o Protection of Pillar Point Marsh is one of the stated policies of San Mateo County’s Local Coastal Program.
o Although not officially part of the Fitzgerald ASBS, Pillar Point Marsh is part of the Reserve and should receive a high level of protection from water quality impacts.
2. Placing half of the Coastside’s office space adjacent to the Reserve would increase human use, pressure, and impacts on the Reserve.
o A particular concern is increased foot traffic on the bluff and beach adjacent to the development – harbor seals frequently use this area.
3. The development would degrade water quality in Pillar Point Marsh.
o Pillar Point Marsh is directly adjacent to the proposed development.
o Beneficial uses of Pillar Point Harbor are already considered impaired due to coliform bacteria and mercury. (http://www.swrcb.ca.gov/rwqcb2/water_issues/programs/TMDLs/303dlist.shtml)
o Although 80% of stormwater is anticipated to be captured on site once the project and all of the stormwater mitigation measures are completed, this would leave 20% or perhaps more to flow directly into Pillar Point Marsh.
- This runoff would contain a complex mixture of many contaminants, including coliform bacteria from pet waste; many pollutants emanating from vehicles, including heavy metals such as mercury and copper, polycyclic aromatic hydrocarbons, other petroleum hydrocarbons, pesticides, and many others.
- Supplying more mercury, even small amounts, to the Marsh could increase mercury accumulation in the Marsh and Harbor food chain and exacerbate the existing beneficial use impairment due to mercury. (http://escholarship.org/uc/item/9fm1z1zb)
- Estimates of the amount of stormwater that would be captured may be overstated. The underlying soil type and size of rain gardens and swales would not be able to capture water from precipitation larger than 0.2 in/hr. During these frequent larger storms water and contaminants would run off the project site.
o Sludge and treated wastewater would be applied to agricultural areas on the property – the sludge and wastewater would contain contaminants that could be transported to the Marsh.
o Accidental spills of fuel or other chemicals could occur on the property and represent another threat to water quality in Pillar Point Marsh.
o Water quality monitoring is needed to determine whether the project degrades water quality in Pillar Point Marsh. No monitoring has been performed to date or is proposed in the EIR.
- Monitoring of current pre-project conditions is needed to establish a baseline. No monitoring has been done to determine the existing water and sediment quality in the Marsh.
- No water and sediment quality monitoring in the Marsh was proposed in the EIR.
1. The lowest portion of the proposed project is just above the FEMA floodplain.
2. Sea level is expected to rise 3 to 4 feet by 2100, making this area even more flood prone as time passes – this needs to be factored in and was not discussed in the EIR.
3. El Niño conditions can combine with high tides to also cause flooding at higher elevations (“San Francisco Bay: The Coming Flood?” http://www.sciencemag.org/cgi/content/full/325/5948/1637). It is unclear whether this was considered in the decision to place the FEMA floodplain south of West Point Avenue.
4. The area could clearly be at risk in the event of a tsunami, as indicated in the EIR. The EIR states “… any development in this area would need to take into account the effects of tsunami action on structures and people.” The EIR does not indicate how the potential effects of tsunami action were taken into account in the project design.
5. As stated in the EIR, a combination of high groundwater and heavy rain could also cause local flooding onsite.
6. As stated in the EIR, other than onsite stormwater storage, the current project plans do not indicate any particular measures planned to mitigate for onsite flooding.