Gilman Street Playing Fields Berkeley
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Re: Gilman Street Playing Fields Berkeley, Alameda County, APN# 060-2529-001-03 Waterfront Specific Plan Amendment, Rezoning, Project Development and Project Operation
L A Wood, July 13, 2005. To the Department of Parks, Recreation and Waterfront

The Gilman Play Fields project is ill conceived and the Environmental Initial Study falls short of showing that the creation of the children’s play fields at that location would not become a public health concern. The proposed project is inconsistent with our General Plan, area zoning and lacks adequate public health and environmental protections. Please consider the following:

Air Quality
First, it should be stated for the record that freeway emissions are very toxic. The closer one is to Highway 80, the worse the air quality is likely to be. This isn’t rocket science, but health science. Further, in the last decade, numerous freeway studies have confirmed the association between highway auto emissions/traffic density and many respiratory problems including asthma and bronchitis, increased hospitalizations for asthma and the decrease in lung function in some children. These are all potential concerns at the Gilman Street project, especially for those already at risk.

The central argument made by the Initial Study for justifying the health safety of placing soccer fields next to the freeway is the questionable claim that the site would most often, while in use, be upwind from freeway emissions. This claim fails to fully account for the days where the site is downwind or when there is no wind. Consequently, the Initial Study substantially underestimates the poor air quality days that could be expected when the proposed site is actually use in.

It is presumed that the fields could potentially be used 365 days a year. What would be the health consequences for those children on-site during days of no wind or downwind? What percentage of days with no wind or downwind per year would be acceptable from a public health perspective? Ten percent, twenty percent, thirty percent, or more?

Since most of the users of the play fields will be children, it is even more important to verify the project’s claims of adequate air quality mitigation by direct, site-specific monitoring of both weather conditions and freeway emissions. This is a critical health assumption and the proposed project plan should show this to be true. Note: To date, there has been virtually no on-site air monitoring at the proposed Gilman Street Play Fields.

Recently, the City of Berkeley went on a campaign to screen school children for asthma. These studies show that the 94710 zip code area encompassing the length of the freeway in west Berkeley, and including the Gilman location, has the highest rate hospitalizations for asthma in our city. West Berkeley, and specifically the 94710 zone, should be recognized as an asthma-sensitive area. No project like the Gilman Street park should be constructed without the requirement of extensive on-site air monitoring

The Gilman Street project represents a major shift in land use. It should be noted that the California State Air Resources Board (ARB) has recently updated its land use manual and the guidelines for new sensitive land uses along freeways (those with 100,00 vehicles/day). The new ARB criteria identify schools and play fields as sensitive land uses. The ARB states that locating play fields in high traffic freeway and emissions areas should be avoided. The Interstate 80 traffic that passes the proposed site each day is said to exceed 250,000. Clearly, the Gilman Street Play Fields project falls within the ARB’s definition of new, sensitive land uses. Given this, the rezoning of the Gilman Street site demands a more formal environmental analysis.

Health Risks
It is evident that the use of the Gilman Street Play Fields during late weekday afternoons would most often correspond to the worst rush hour traffic and area emissions. It is also a recognized fact that traffic density will continue to grow, and more and more cars will be added to the commute. The future development of Golden Gate Fields and a possible ferry terminal at Gilman will also add to the area’s congestion and air pollution. These issues are not accurately factored into the health risk assessment, nor is the distance from freeway emissions and traffic densities. As a result, the risk assessment gives a distorted picture of the location and minimizes the potential health risks.

It should be noted that stationary sources, such as foundries, have been ignored in this evaluation. Residents have reported smelling the steel foundries, like Pacific Steel Castings (PSC) located at 2nd Street and Gilman, all the way out to the edge of the Bay Trail in Berkeley. The stacks of these foundries and other manufacturing concerns are just on the other side of Interstate 80 and the proposed play fields. Their emissions will certainly impact the playing site on days when the wind blows toward the west. Where is the evaluation of the industrial emissions on the play fields?

Smells from west Berkeley industry and the freeway frequently inundate the site as well. These odors are regularly reported by those in the project’s general location as nauseous and pervasive in the many complaints to the Bay Area Air Quality Management District (BAAQMD). In fact, the immediate area next to the proposed playfields that includes the foundries is cited in more complaints about smells with BAAQMD than any other place in Berkeley, or for that matter, the Bay Area. On-site monitoring of odors for one continuous year should be required before any project at the proposed Gilman site is approved.

Several years ago, the City of Berkeley created a similar playing fields project at 4th and Harrison, not far from the Gilman Street site. The Harrison Fields had, and has, serious problems associated with air quality. At first, the city argued for the rezoning of the Harrison site based on the idea that the air quality wasn’t so bad, providing children didn’t spend too much time there. However, air monitoring has revealed a much different and more extreme picture. The PM10 particulate matter at Harrison Soccer Fields exceeds the state’s health standards more than 100 days a year!

The Harrison Fields zoning review has required that users of the fields be made aware of the industrial and environmental issues associated with the site. Parents of children playing soccer there must sign an acknowledgement that they had been informed about the special conditions of the park since it is situated in the middle of an industrial zone, including concerns over noise, smells and poor air quality.

In addition, the city is currently required to post signs at the Harrison site warning users about the poor air quality. Because the proposed Gilman Street site would be subject to equal, or even greater pollution levels, this same public noticing process and signage should be required of all users at the Gilman Street location, if the project is approved. Further, there should be some attempt to better understand all site emissions, including diesel, since Interstate 80 carries considerable big truck traffic. As stated above, the Gilman Street Play Fields should be required to air monitor the site emissions for at least one continuous year. This data should be used to better understand the real health risks.

Wind
There are no adequate mitigations for the strong winds that blow in from the ocean. As acknowledged by the project evaluation, the placement of trees along the western portion of the site does little to change the wind speed. A clearer understanding about the degree of health concerns connected to persistent, moist ocean winds, especially on small children is needed. The project should also evaluate the strong winds and emissions when the proposed site is “in use” and, “downwind from emissions/freeway”. The tot lot proposed in the southwest corner near the shoreline should never be constructed at this site.

Additionally, there should be a zoning requirement for the Gilman Street Play Fields project to place a wind monitor on-site for one continuous year. Collected data would be used to create a site-specific wind rose chart and to obtain greater understanding of actual site wind and weather conditions. This data would then be used to develop a more accurate assessment of health risks and site conditions.
More should also be known about the outgassing of methane gas and its concentrations on the entire site. It should be determined if the perculation/outgassing of methane gas is impacting other soil-bound gases, Volatile Organic Compounds (VOCs), and drawing them to the surface, too.

Noise
As would be expected, the noise level at the proposed freeway site is extremely high. That’s why freeway sound walls are constructed. The location of the field is in the worst place for auto and industrial noise. Given the fact that this is a children’s park, the concerns over high levels of noise are serious. The site should be reevaluated for noise to verify the high on-site levels and further, the city should place warning signs about the possible health effects from prolonged exposure to high levels of noise.
Site Soils & Contamination

It is important to understand that the cleanup and evaluation of the Gilman Street site was overseen by the Regional Water Quality Control Board (RWQCB). Historically, the RWQCB allows for the most minimal protocol of soil sampling in evaluating a site. This is what has happened at the Gilman site. The limited samples, so few, so far apart and so shallow, reveal an incomplete picture about potential contaminants. Perhaps this limited investigation would be appropriate for an industrial use, but it certainly is not adequate for parks and children. Even at the City of Berkeley’s Harrison Park, which had the oversight of the city’s Toxics Management Division, soil and site evaluations were much more extensive and rigorous.

There are serious concerns about the proposed “capping” of the Gilman Street Play Fields site. Since the groundwater levels are shallow, the potential for the perculation of contaminants may present problems that covering the site with dirt will not resolve. This is another justification for a more thorough soil investigation and cleanup process. The asphalt that now covers a part of the site should be removed and disposed of properly.

Note: Past site cleanup relating to parcel sale/transfer(s) has also been minimal. Site investigations/cleanups were done under the umbrella of the RWQCB and the board’s “containment zone policy”. The RWQCB idea is to leave pollution in place if you can, thus creating “areas of non attainment” or lowered cleanup standards.

Traffic
Traffic, traffic and more traffic, is the current picture at the base of Gilman Street and Interstate 80 at rush hour with cars and trucks stopped on the freeway, just idling. Local streets, like Gilman, are crowded with traffic from the evening commute flowing out of the Oceanview District in Berkeley. It is difficult to imagine Berkeley children riding their bikes down Gilman Street, through the underpass of I-80 and then past the freeway’s on ramps and off ramps in order to reach the park location. Unfortunately, the times Gilman Street users would most often frequent the proposed fields are those times in the week when the area has the greatest traffic congestion.

The project review and rezoning for the Harrison Park, not far from the proposed site also raised concerns about Gilman Street traffic because the park was in the middle of a manufacturing district. The city, which was also the developer, brushed aside all concerns saying the Gilman Street interchange would solve all the area’s traffic problems, including kids on bikes. A half a dozen years later and the traffic mitigations for the Harrison Project have not been delivered. Now, the Gilman Street Playing Fields proposal has offered up that same rhetoric about the area’s transportation and future.

Without a doubt, the Gilman Street project has even greater traffic density issues and the location is even less accessible to children than the Harrison Park, just several blocks away. Even with the interchange, the area’s traffic will continue to represent an obstacle for children going to the park on foot or on bicycle and is a huge safety concern.

Until the interchange is completed, the Gilman project needs to put in place, immediately, safety mitigations that will actually insure that children who may be traveling to the park alone can safely navigate that area of Gilman Street. This mitigation(s) can’t wait like the city’s Harrison Park project has had to or until the I-80 interchange is built. We certainly can’t wait until Berkeley experiences a fatality linked to the proposed Gilman Street or Harrison Parks. This is not a zoning problem that will work itself out over time. The impact of traffic on the proposed site will only grow over time as will the danger.

Alternatives
What about alternatives? A better alternative would entail, at a minimum, the relocation of the play fields to another part of the East Shore Park that was substantially further away from the freeway and Oceanview industry emissions. The project’s play fields could be scaled down or split up to occupy one or more sites. The city currently holds the old corporation yard site of about 5 acres. Located in a residential R2 area, the Corporation Yard could serve as the playing fields. The Corporation Yard’s air quality is far superior to the Gilman site as is the traffic/transportation considerations. The Derby Street property at Martin Luther King Way affords another possible soccer site.

There seems to be the assumption that all of the project’s play fields must be located in Berkeley, but the proposal for the Gilman Street fields, though based in Berkeley, is a regional project. Therefore alternative sites for the play fields should have been explored in the cities of the other members of the Joint Exercise of Powers Agreement, specifically Richmond, El Cerrito, Albany, and Emeryville. Where is the evaluation of these alternative sites?

The Gilman Street project, like a number of other west Berkeley projects, has raised conflicts about air quality and land use. The city has failed to seriously look at this growing rezoning problem in West Berkeley. The city’s projects come to the zoning process piecemeal. Even when challenged, questions about actual project impacts to the area and their rezoning inconsistencies are never fully addressed. Harrison Skate Park and Soccer Fields and the Ursula Sherman Village transitional housing for the homeless in the middle of Oceanview’s industrial manufacturing sector are prime examples of this.

The project consultants reference how consistent the play fields are with the General Plan. An argument could be made against the project as well, based upon other sections of the General Plan. It just depends on how you wish to define it or in this case, how consultants decide to package the project. This is a very bad package that stretches the over bounds of our zoning and ignores too many environmental protections. The Gilman Street Project should be required to complete a formal Environmental Impact Report to answer all the critical questions regarding the project, site and the city’s rezoning process in northwest Berkeley.

This is the second project of the “same” type to be placed in northwest Berkeley that has required a special rezoning process. First, there was the Harrison Soccer Fields and now Gilman Street Play Fields. The cumulative impacts of these projects and new uses trigger the requirement for an EIR to be undertaken by the City of Berkeley. Moreover, the public should have a formal opportunity to discuss these extreme shifts in rezoning as they pertain to the area’s development.

The rezoning for the fields has the potential to adversely impact other area businesses. This project would seem to be intrinsically unfair to area businesses, like PSC, who have been under fire for odor nuisance abatement. The proposed fields will bring more people next to PSC’s foundry and that will invariably cause more nuisance complaints to be generated. Will zoning require persons using the fields to be exempt from complaining about the smells of the areas and those coming specifically PSC?

Finally, where is the City’s new precautionary principle on this project’s checklist? It should be more than a slogan. This project is not a sustainable development, but simply throws all caution to the wind in the hope it will literally blow the right way. The Gilman Street project should be relocated to a more appropriately zoned and healthier location(s).

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