Proposed General Plan Amendment Regarding Biotech East of 101

April 16, 2024
City of Millbrae City Hall
621 Magnolia Ave
Millbrae, CA 94030

Subject: Proposed General Plan Amendment regarding Biotech East of 101

Dear Mayor Fung and Millbrae City Councilmembers,

The Sierra Club Loma Prieta Chapter’s Sustainable Land Use Committee (SLU) advocates on land use issues in San Mateo and Santa Clara Counties.

BioSafety Level (BSL) labs: We recently learned that the Millbrae City Council agreed to approve a minor amendment to the General Plan to allow Biotech use at BioSafety Levels (BSL) 1 & 2 east of Hwy 101 and to ban BSL 3 & 4. BSL 1 & 2 are lower risk labs, while BSL 3 & 4 are higher risk, high-containment labs classified as such because they do research with airborne and highly infectious agents that are dangerous and more difficult to control.

This decision is consistent with the City of San Carlos which allows BSL1&2 and has banned BSL3 labs citywide, for community safety, and Redwood City which, in their downtown specific plan, requires a Conditional Use Permit (CUP) for BSL1 & 2 and bans BSL3.

BSL3: We also learned that BSL3 laboratories may be allowed in some areas of Millbrae with a CUP (conditional use permit). We see this as problematic from an environmental and a public health and safety point of view. County Emergency Response is not equipped nor is it funded to deal with the hazards related to an inadvertent release of novel, airborne, highly contagious infectious agents as are allowed only in the high-containment life science labs such as BSL3 and BSL4 labs.

For public safety reasons, we strongly recommend the City revise the existing Planning Code, in order to avoid serious potential hazards to the community, and ban high containment labs, such as BSL3 & BSL4 labs, anywhere in the City. This potential new hazard, from novel viruses such as was encountered with Covid19, should also be listed in the Safety Element of the General Plan to ensure that high-containment labs are not created in the City.

The discussions in San Carlos about BSL3 labs concluded that banning BSL3 labs would have minimal impact on the economic vitality of the City (staff research predicted less than 1% potential revenue from BSL3 labs) or the desirability of the Peninsula cities as a location for future biotech development.


Respectfully Yours,

Gita Dev, FAIA, Chair
Conservation Committee
Sierra Club Loma Prieta Chapter

CC:
Millbrae City Clerk, Elaine Tran
Millbrae City Manager, Tom Williams
Millbrae Community Development Director, Andrew Mogensen
James Eggers, Executive Director, Sierra Club Loma Prieta Chapter
David Crabbe, Sustainable Land Use Committee, Sierra Club Loma Prieta Chapter