What is Happening?
The City of Brisbane is considering a General Plan Amendment, and a Design Permit to develop a very large, 1.3 million square-foot warehouse, 100’ tall (like an 8-story building), within the Guadalupe Quarry site, for 800 - 1,500 employees. The proposed project would involve annexation of approximately 104 acres into the City’s limits.
Why Is It Important?
The warehouse or distribution center project will introduce traffic, potentially for all hours of the day and night, light pollution and air pollution, and will reduce and decimate critical wildlife habitat. It also includes a new access road with regrading, causing erosion problems, and loss of many heritage and habitat trees. It could be a 24/7 operation.
Importantly, it also proposes to make changes to the San Bruno Mountain Habitat Conservation Plan (HCP) for the whole State and County Park. This is critical because the Park includes 14 species of rare or endangered plant life, as well as host and nectar plants of endangered butterflies. The endangered or threatened butterflies include San Bruno Elfin, Mission Blue, Callippe Silverspot, and Bay Checkerspot butterflies which are found in only a few other places in the world.
The project should be rejected. The EIR (Environmental Impact Report) for the project should also be rejected because
- It wrongly identifies this project, with a minor decrease in size, as the environmentally superior alternative, rather than the original much smaller project,
- It does not include required information on its assumptions about VMT and GHG emissions,
- The mitigation measures proposed for hydrology, erosion, biological impacts, and water use are not adequate to mitigate the impacts it will have,
- It hugely downplays the aesthetic impact of the project which will create visual blight incongruous with the surrounding open space, light pollution and a long access road, and
- It arbitrarily sets a high construction noise threshold at 86 decibels (dBA), which exceeds safe exposure levels, while CEQA’s (California Environmental Quality act) stated objective is to protect residents from excessive noise
What can you do?
Urgently send a short email to the Brisbane City Council (CouncilMembers@brisbaneca.org) asking them to reject the EIR as inadequate, and to deny the project as proposed because of the enormous environmental impacts caused by this proposed huge project that cannot be mitigated.This enormous mega-project is out of scale with Brisbane’s community. Its impacts on residents as well as on wildlife cannot be adequately mitigated and are beyond acceptable levels.
Sample language for a letter
It would be good if you can personalize this and add a sentence at the beginning to introduce yourself.
[Your Name]
The Draft Environmental Impact Report (DEIR), for the proposed project, under the Environmental Quality Act (CEQA) has numerous flaws and inconsistencies in the analysis of environmental impacts and the adequacy of proposed mitigation measures and it fails to meet CEQA standards for environmental review. To comply with CEQA, the DEIR must be thoroughly revised to address these deficiencies and recirculated for public review.
A critique of the DEIR for the 1.3 million sf proposed project finds many flaws in the DEIR including the following major issues:
- Selection of the Environmentally Superior Alternative is incorrect
The DEIR designates Alternative 1 (approx 1 million sf) as the “environmentally superior alternative,” but our critique deems this choice baseless and inconsistent with CEQA requirements. Alternative 1 does not avoid or significantly reduce project impacts. Conversely, Alternative 2 (approx 350,000sf) which should qualify as the true environmentally superior alternative, has been manipulated to appear as if it introduces additional impacts. The report highlights that Alternative 1 would also result in over 20 acres of new disturbance on top of the 81.5 acres already affected by the existing quarry, while Alternative 2 could prevent this additional disturbance.
- Plan Bay Area and Vehicle Miles Traveled (VMT)
CEQA mandates comparing impacts against existing conditions rather than speculative future scenarios. Therefore, the DEIR’s reliance on Plan Bay Area future projections for its vehicle miles traveled (VMT) analysis is called into question. The assumption that the project will reduce trips and trip lengths compared to current conditions is deemed unrealistic. The DEIR fails to provide evidence that new distribution centers would lead to closures or operational changes in existing centers. Consequently, the VMT, air quality, and greenhouse gas (GHG) emission estimates should treat project-related trips as net additions to existing levels. The concept of “offsetting” to reduce VMT is criticized as unsupported and impermissible under CEQA, necessitating revised analysis and public review.
- Hazards and Hazardous Materials
This mitigation measure, Mitigation HAZ-1, is insufficient for addressing grading and stormwater impacts, leaving these effects significant. A new, effective mitigation plan is necessary.
- Hydrology and Water Quality
Threshold HYD-3: Erosion impacts are deemed significant, particularly given the grading of over 100 acres. The DEIR erroneously identifies these impacts as less than significant and omits mitigation measures. CEQA requires effective mitigation to prevent substantial downstream sedimentation.
- Biological Impacts
The assumption that special-status plant surveys remain valid for five years is unrealistic. Annual verification of these surveys is recommended to ensure compliance with CEQA standards. See Mitigation BIO-1
The DEIR proposes mitigation measures BIO-3 to avoid direct impacts on monarch butterflies but allows for the elimination of roosting habitat, further endangering the species. Mitigation should include rerouting or redesigning the access road to protect this critical habitat.
- Greenhouse Gas Emissions
The assumptions that the project would “offset travel” anticipated in the future should be dismissed as unsupported and inconsistent with CEQA’s requirement to assess impacts against existing conditions. The project is expected to substantially increase local and regional GHG emissions, necessitating revised analysis. See Threshold GHG-3
- Water Use
The DEIR lacks evidence demonstrating that the proposed new groundwater supply well can provide sufficient quality of water or quantity of water for irrigation. Further verification and review of appendices are needed, with revisions made to ensure compliance. See Mitigation UTIL-2
- Aesthetic Impacts
The aesthetics analysis in the DEIR is heavily criticized for downplaying significant visual impacts. Photo simulations clearly show that the project would cause substantial aesthetic changes, creating a visual blight incongruous with the surrounding open space. The DEIR’s conclusions of “less-than-significant impacts” conflict with the evidence and applicable General Plan policies. CEQA requires accurate assessments of such impacts, and the DEIR must be revised and recirculated to reflect the project’s significant visual impacts.
- Construction Noise
The DEIR arbitrarily sets a construction noise threshold at 86 decibels (dBA), which exceeds safe exposure levels. This threshold is inconsistent with CEQA’s stated objective to protect residents from excessive noise. A lower, reasonable threshold should be adopted to align with public health standards and CEQA requirements