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