June 23, 2023
Mayor Gee, Redwood City Clerk and Members of the City Council
City of Redwood City
1017 Middlefield Road
Redwood City, CA 94063
Via email: council@redwoodcity.org
paguilar@redwoodcity.org
Thank you for distributing this letter to your city manager and council members.
Subject: New Redwood Life Precise Plan and EIR
Dear Mayor Gee and Members of the Redwood City Council,
We believe that it is premature to start a new Precise Plan for the Life Sciences industry and especially the associated EIR because there are several items that are not yet adequately addressed.
1. APPLICATION TWICE DEEMED INCOMPLETE by the Planning Department.
- In order for a new Precise Plan to be initiated, it is necessary to have a basically complete proposal. The Redwood Life R&D at 800 - 3400 Bridge Parkway is still an incomplete submission.
We note that projects that request to move forward are, for a variety of important reasons, not always accepted by the City. As a recent example, during the GATEWAY projects selection process, several projects were not accepted.
2. COUNCIL ADVISORIES AT STUDY SESSION ON APRIL 24, 2023
a. MORE COMMUNITY ENGAGEMENT required.
- However, there has been no substantive discussion of industrial concerns with residents or the environmental community.
b. REVISED SCALED-BACK PROJECT ALTERNATIVE
- DIANE HOWARD said “Consider scaling back or moving things around. Listen to what their [community’s] concerns are and their fears. And see what you can do to come back to us with something that you feel is a better project...”
- ALICIA AGUIRRE said “I agree with some of the things that Diane said. And I agree that something that needs more work is the community outreach.”
- JEFF GEE said “I think it would be nice to somehow find a way to see if the community, if the RWS community and the landowner could work together to define a project that works for everybody. And even if it’s smaller than what it is, but it works. And I just don’t get the sense that engagement has come together to produce anything different. And it's moved some things around, but I would encourage somehow we find a way to make that happen. So that we can have serious, real dialogue of what can work out there for everybody. And it just seems to be a missing piece right now.”
The applicant has failed to work with the residential or environmental community to generate a scaled-back project to address concerns.
3. STRATEGIC PLAN GUIDING PRINCIPLE: “ECONOMIC VITALITY” (pg 8)
“Support Redwood City’s economic prosperity by attracting, retaining, and expanding a diverse mix of businesses that meet community needs.”
- ALICIA AGUIRRE in 5/8/23 DTPP Study Session, at 2:02 expressed concerns about Life Science market contraction and sector saturation. She questioned the long term viability of life science lab space demands, asking “how much R&D is going to be in demand when all of this is built?”
- Life Science Market Sector is Contracting. See: White Paper, “The Work From Home Hurricane Has Hit Life Science Offices.”
25 years is a long time for a speculative industrial R&D development as market conditions can change dramatically and, as a practical matter, applicant commitments cannot be guaranteed.
4. AN EIR DOES NOT STUDY THE ENVIRONMENT’S IMPACT ON A PROJECT
- An EIR is required to assess the potential impacts of a project on construction workers, residents, and the environment; it is not required to address the potential impact of the environment (i.e., earthquakes, flooding, future sea level rise) on the project and these risks after completion. Thus, those risks are classified as “no significant impact” even though such natural events and disasters are entirely predictable.
Unfortunately, an EIR for this project cannot properly assess the human health and environmental risks from siting this Life Sciences R&D industrial project in an area with high liquefaction potential and in a FEMA flood zone, on an unlined landfill that is adjacent to residences, and community facilities. This is a shortcoming of the CEQA process.
5. INSUFFICIENT INFORMATION TO EVALUATE IMPACTS FOR EIR
- Unlike other projects, the proposed buildings are speculative “shell” structures, with no percentage given for labs versus office space. This makes it impossible to evaluate environmental impacts as there is insufficient information on proposed allocation of building usage for impacts to be quantified and evaluated.1
In Summary,
The applicant purchased this property in the full knowledge of the Westport Specific Plan and its constraints. The development being proposed is a much bigger campus than was ever imagined by the Westport Precise Plan (which provides protections for the community), with multiple construction phases and a long timeline of 25 years. For a speculative venture, a lot can change in 25 years, in the economy and, with climate change, in our environment.
The 25 year entitlements for a speculative venture includes uncertainty for the City and for the neighborhood, unlike an institutional applicant such as Stanford University which is here to stay.
The current industrial proposal is a large expansion in the middle of a now mature residential neighborhood. It is along an environmentally sensitive nature reserve. It is on a known problematic landfill susceptible to sea level rise, flooding and seismic liquefaction. It is remote from transit and with limited access. It has a huge amount of residential opposition that has not been addressed by the applicant.
- For an industrial project of this magnitude, we support the Council’s advice for the applicant to work with the community and stakeholders to FIRST develop the potential alternative plan that starts to address concerns.
- An EIR should be started only AFTER a more reasonable alternative plan is developed.
We believe it is premature to start an EIR process without an alternative, more realistic plan to study.
We also attach our previous letter to the City Council Study Session on April 20, 2023.
Respectfully submitted,
Gita Dev, Co-Chair
Sustainable Land Use Committee
Sierra Club Loma Prieta
415-722-3355
Cc: James Eggers, Executive Director, Sierra Club Loma Prieta Chapter
Dave Pine, Chair, Board Of Supervisors, San Mateo County
Ray Mueller, Board of Supervisors District 3, San Mateo County
Len Materman, OneShoreline, San Mateo County
1 For example some of the issues that come to mind are:
Quantify traffic generation based on labs versus office space
Quantify energy usage of labs. Also, will rooftop equipment render solar panels impossible?
Quantify water usage of labs. Will there be a need for City emergency water storage to be increased?
Quantify sewer usage of labs? What is the cumulative effect of several lab buildings being added to the
City’s waste treatment plant, especially during storm events?
Quantify waste stream of labs?
Quantify impacts of exhausts of labs on residences - different BioSafety Levels (BSL) have increasingly high exhaust system requirements
Impact on Fire Department and Emergency Management based on types of BSL labs. Does project build-out require a new Fire Station given proximity to residences.