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Coyote Point Status

Last night the Burlingame Planning Commission found the environmental impact report (EIR) on the 301 Airport Boulevard development to be sufficient and they selected Janaury 31, 2000 as the hearing date for consideration of approval of the project. The hearing will be at Burlingame City Hall - 501 Primrose Avenue in Burlingame at 7:00 p.m.

The City Resolution does include language which makes it clear that the Commission has no intention of allowing the criteria for significant impact used in the EIR to become a standard validated by the Commission which might be used in future cases.

The test of impacts to WNW winds requested by Commissioer Deal has been left out of the EIR process and the test will be conducted at the election of the developer.  Deal made it clear that he would need to see such test results to make a determination on the project.

The 1/31/2000 meeting is an important one. The builder is asking for a variance to allow him to build 83' buildings where the height limit is 65'. One of these buildings will be located 200' from the water's edge on the Coyote Point Park side of the property.

Peter

11/22/99

Info on the 11/22/99 Planning Commission study session follows. The matter has been continued to JANUARY 10, 2000 for the consideration of project approval and certification of the EIR.

The Planning Commission conducted study session on the 301 Airport Boulevard project on 11/22/99. I followed up on my report to the City by making comments from the floor regarding the failings of the most recent wind tunnel study. Dan Levin of Glenborough Realty Trust followed up by with comments generally along the lines that myself and the SFBA were unreasonable and dishonest.

The Commission decided that an additional test of WNW wind direction for the revised project would be reasonable and Commissioner Jerry Deal took the lead in requesting the test of WNW wind conditions and Commissioner Vistica concurred. Deal also asked if the applicant or planning staff could make an effort to determine why the wind tunnel tests showed such disproportionate impacts between the plan with three 5-story elliptical buildings and the plan with three 7-story elliptical buildings.

On the whole the Commission seems to still be concerned about the size of the project. Most had questions about ways they might get better picture of what the traffic impacts would look like in the real world. Commissioner Keighran asked how useful it was to trim tree heights to 8' to reduce impacts to wind if buildings were 82' tall where the area height limit is 65'. Commissioner Vistica said that he needed to hear a clear justification as to the large project size in light of the impacts. Keighran and Vistica both had concerns that amenities requested by the Commission (day care/restaurant) had not been included in the revised plans. Commissioner Dreiling noted that the developer was promising significant tax revenue for the City, but questioned how good a deal cash for impacts would be where the community will have to live with those impacts.

It will be important for the Commission to hear from the community on January 10th. The Commissioners are all very concerned about the impacts and need to hear from the community. The meeting will be on a Monday night and will be held at Burlingame City Hall at 7:00 p.m.

Peter Thorner

11/8/99

 The developer for the drive-in property located west of the Coyote Point launch and sailing area, 301 Airport Boulevard, has submitted a revised development plan.

It looks like action on the new development proposal for the drive-in property west of Coyote Point Park may come down during the holidays. A Planning Commission study session could occur as soon as November 22nd although a more likely date is December 13th.

The new configuration is three 5-story buildings with a total floor area of 480,000 square feet (s.f.) which would equate to a floor area ratio (FAR) of about 0.68. The buildings are reportedly 90' tall. The buildings are somewhat elliptical in shape and are now oriented narrow side to the wind.

The previous configuration that was rejected by the Planning Commission was five buildings ranging from 3-7 stories, most of which were oriented broadside to the wind. The previous configuration had a total floor area of 635,868 s.f. and an FAR of 0.90. The building heights ranged between 52 and 105 feet.

The property at 301 Airport Boulevard lies within the Bayfront/Anza area. The area plan for Bayfront Anza allows for FAR up to 0.90, but the average FAR for office developments built since the area plan went into effect is 0.57. The FAR for the only similarly sized project in the Bayfront/Anza area, 555-557 Airport Boulevard is 0.46.

The Bayfront/Anza area has a building height limit of 65'. The inclusion of 90' buildings would require that the Planning Commission grant a variance. The SFBA has previously argued that the development should be built within area height limits.

In the area there are at least three major parcels that may be developed for office and/or hotel use at future dates. These include the Hertz lot at 300 Airport Boulevard, the State of California lands near Kincaid's Restaurant, and the land west of the Sheraton Hotel. Traffic impacts for the new configuration should be reduced proportionally to the reduction in the FAR.

WIND TUNNEL TESTING

The developer commissioned a wind tunnel test for the revised plan. Dr. Bruce White conducted the test at University of California at Davis. Dr. White is well qualified when it comes to wind tunnels and has an excellent reputation. The test was for west winds only. The test showed negligible impacts as measured by turbulence intensities (TI).

In the existing conditions, areas of higher turbulence (above 20% TI as measured in the wind tunnel) extend 300-400' past the Airport Boulevard bulkhead. For the previously proposed development, areas of higher turbulence were expected to extend over 1,300' past the Airport Boulevard bulkhead.

For the new configuration, areas of higher turbulence extend 200-400'past the Airport Boulevard bulkhead and cover roughly the same area as the existing zone of higher turbulence. In addition, there is an area well downwind where TI is projected to decrease below 15%.

During the summer the developer presented wind tunnel data for a project which appeared to have the same building shapes and locations as the new configuration, but which used three 7-story buildings instead of three 5-story buildings. The wind tunnel data showed a primary area of higher turbulence extending 1,200' past the Airport Boulevard bulkhead and secondary bubble of higher turbulence extending out to 1,500' past the Airport Boulevard bulkhead. In light of these results, one would have expected the new configuration to have impact closer to those cited above since the 5-story building are roughly 5/7 of the height of the 7-story buildings and similar in configuration. Typically, the distance turbulence travels is proportional to the height of the blockage where all other variables remain the same.

The wind tunnel results that show no serious increase in turbulence intensity for the new configuration seem unexpected. Dr. White said that he was surprised by the results and expected them to be worse, but he also said that he believed the results were accurate. The minimal impact from the three 5-story buildings seems problematic in light of the fact that three 7-story buildings in an almost identical configuration had a major negative impact that was on a par with the impacts from the previously proposed project which was rejected by the planning commission.

In the previous configuration, it was agreed that the worst impacts were going to be for west wind conditions since the buildings essentially created a wind block with the wide sides of the building square to the west wind. The new project is designed to be more west wind friendly with a narrower profile relative to the west wind and buildings that are designed to be somewhat like a wing. As the wind deviates from west, the wind will flow less cleanly around the buildings just as wind flows less cleanly over a wing as it deflects to a steeper angle. At some point a wing reaches an angle where it stalls and creates very turbulent airflow. In theory there may also be an angle off of west at which the airflow going around the buildings becomes much more turbulent.

Peter

6/15/99

We Won!...7-0

The Commissioners expressed concern over the EIR they had previously voted to find sufficient. They asked the City Attorney about revisiting the EIR but ultimately decided not to take action on the EIR because they were voting to deny the project without prejudice. The denial means the developer can come back, but the commissioners made it clear they only wanted to see a seriously reduced project. Two commissioners said a new plan should be wind tunnel tested. One commissioner suggested no buildings over three stories on the east side of the property. Another said buildings need to be rotated. The developer basically needs to do a full redesign to come back. That in turn should trigger a whole new EIR which will hopefully be done right.

Now we wait to see if the developer will appeal to the City Council. If he does, I think he has a tough sell as the vote was a unanimous 7-0 and their was great turnout from both  the windsurfing community and the local community that would get hit with traffic impacts.

Peter

6/9/99

Information re. June 14th Planning Commission Meeting

6/4/99

The developer of the property upwind of Coyote Point Park is on calendar for approval of his project -
Date: June 14th @ 7:00 p.m.

Place: Planning Commission
501 Primrose Road
Burlingame, CA 94010

This may be your last chance to have your say. The Planning Commission has the power to approve the project on 6/14 if they so choose. A number of Commissioners have expressed concerns about windsurfing impacts and they should be hear from us. On 5/24, the Commission asked the developer to explore new alternatives to reduce the impacts to windsurfing and to the views and it appears the re-submitted plans will not address those concerns. Let the commission know that the developer should not be rewarded with the granting of exceptions to height limits, view blockage limits, etc.

Next Thurday I will have a copy of the Staff Report and will have had a chance to review the design changes. At that time I will post up more specific information. Comments on the specifics will have to be made in person since letters sent after next Thurday will not reach the Commission until it is too late. Speakers at the Planning Commission are limited to three minutes each, so it is important to be organized and to hit topics others have not hit on.

The developer has apparantly made very minor changes to the project following requests by the Planning Commission that he provide alternative plans which looked at reducing wind impacts by downsizing, rotating buildings, or relocating buildings. None of the buildings have been rotated or moved. The overall square footage in the revised plan is apparantly reduced by less than 1% and remains in the 635,000 square foot range. The parking deck has apparantly been lowered to the Airport Boulevard curb level (down a foot or two) so that the project technically complies with lot coverage guidelines which it previously exceeded. The builder still needs an exception on exceeding building height limits for the 6-7 story buildings planned for the west side of the property. The Commissioners should be reminded that the developer failed to provide a real alternative as requested following the 5/24 Palnning Commission meeting.

It sounds like the developer is submitting the "4-4-4-6-7 option" which was previously presented to the SFBA as the less desirable of two developer options (the more desirable was the 4-3-4-7-7 option). The buildings nearest Coyote Point would be 65' measured curb to roof but would be about 85' when measured from mean sea level to the top of the penthouse/mechanical sheds.

The first three numbers in the option names refer to the heights of the three buildings closest to Coyote Point. The last two numbers in the option names refer to the heights of the two buidlings farthest from Coyote Point. The
original plan was a 5-5-7-5-3 configuration with tallest buildings near the water and the 7 story building near the corner toward the ASD windsurf shop. While there is some benefit from reduced building heights near the water, there is also an increase in the impacts from the taller buildings

Peter Thorner
Chairman, Coyote Point Committee
San Francisco Boardsailing Association

5/25/99

The Burlingame Planning Commission considered the development near Coyote Point (301 Airport Boulevard) as a "Study Item" last night. They did not take any comment from the public or the developer. On a study item, they essentially express concerns and make requests for additional information from the developer and City Planner who are then expected to respond to those requests. The next meeting is on the project is conditionally set for JUNE 14th, depending upon whether or not the developer has responded sufficiently in time for that meeting date to be viable. Once the Commission is satisfied that they have the information and the alternatives they want, they will move forward with the approval process and public comment will be important.

The San Francisco Boardsailing Association has received strong support from non-profit organization Save The Bay (see www.savesfbay.org). They are planning a grass roots letter writing campaign and have provided legal guidance which should allow us to intelligently deal with the failings of the environmental impact report/CEQA process. This is a great time for us all to consider the environmental as well as the recreational needs associated with the Bay and the possibilities that cooperation between like-minded organizations offers. Save The Bay is already making great efforts to bring information about the SFO runway expansion plans into the public eye.

The following is a summary of what the Commissioners asked/expressed (in the speaking order) :
Commissioner Dreiling wanted an explanation of why so many exception were neccesary for the project. He expressed concern about the project having being automobile oriented with all of its' density concentrated in the middle of the property amid a "sea of parking." He mentioned that this has impacts on the wind.

Commissioner Ann Keighran indicated that she would like to see the buildings within the area height limit and she indicated that she was very concerned about the density of the project. She indicated that she would like to see the grouping of buildings reversed so that the group of three buildings is farther from the Coyote Point sailing area and the group of two buildings is nearer Coyote Point. She also requested information on the size of the drive in screens.

Commissioner Stanley Vistica said he felt that the project was too big for the infrastructure. He said he would like to see a reduced alternative which respected the exisiting limits on height, lot coverage, and view corridors. He noted that the developer had been blind-sided by the windsurfing issue and that he would like to see the developer take some time to address the wind issues.

Commissioner Jerry Lee Deal said he shared Keighran and Vistica's concerns. He asked that the developer further examine view impacts and that the developer address San Francisco Boardsailing Association concerns. He asked for an explanation of why the project was so tall. He said he would like to see plans including rotation of buildings to reduce wind impacts, elimination of the building closest to the bulkhead nearest Coyote Point, and shifting of taller buildings to the west side of the site. He asked if new plans would go to the wind tunnel and was advised by City Planner Meg Monroe that new plans would be reviewed by the expert.

Commisioner Joseph Bojués said that he echoed comments of those who preceded him. He said he wanted a stronger rational for the deviations from the area plan. He indicated that he would like to see the project scaled back. He indicated that he also specifically echoed other comments as they regarded layout.

Commissioner David Luzuriaga wanted an explanation of why so many exceptions were necessary. He wanted to see comparisons of wind impact between the site with movie screens included and the site under proposed project conditions. He said he was disappointed in the architecture and wondered why the rendering/elevation he had obtained from CB Richard Ellis (commercial brokerage hoping to lease the new office space) differed from those submitted to the City.

Commissioner (Chair) Michael Coffey noted that the project was meeting minimum parking requirements while "maxing out" the size/floor area. He also  said he was concerned about traffic issues including those traffic impact which will be felt in the City of San Mateo. He suggested that the City of San Mateo should be invited to submit further information as to what impacts they expect.

The next Planning Commission hearing regarding the 301 Airport Boulevard development is tentatively scheduled for Monday, June 14th. If that meeting is to go forward, they must give public notice by Friday, June 4th. I will send out the word on June 4th as to whether the meeting has been delayed or not.

When the issue comes before the Commission it will be up for approval. The Commissioners can either Accept, Deny, or Deny Without Prejudice. If they Accept whatever the developer has brought back at that time they may still put additional conditions on the project at their discretion. If they Deny Without Prejudice, they are essentially saying they do not like what they see, but they are leaving the door open for the developer to make modifications which might make the project conform to what they would be willing to approve. The developer would likely return to the Planning Commission with the project at some later date following a Denial Without Prejudice.

If they they issue a flat out denial there is a likelyhood that the developer would appeal the denial to the City Council. The developer would have 7 days to appeal and the Council would deal with scheduling the appeal hearing at their next session.

Whatever modifications the developer makes will likely be evaluated in the Planning Department Staff Report which would be released June 10th. Once I get my hands on that report, I will sent out the word as to the modifiacations if any and the City Planners recommendation. In the meantime, those who wish to comment need to reserve June 14th @ 6:00 pm. The Planning Commission meets at Burlingame City Hall- 501 Primrose, Burlingame.

Written comments may be sent to the City Planner, but any comments on or after June 10th (when the new information on any modifications comes out) are not likely to reach the Commissioners before they take up the matter on June 14th. As such, more specific comments about the proposed developement will need to be made at the Planning Commission meeting.

Comment letter may be sent to:

Meg Monroe
Planning Director
City of Burlingame
501 Primrose Street
Burlingame, CA 94010

- Peter Thorner

5/19/99

Meg Monroe, City Planner    May 19, 1999
City of Burlingame
501 Primrose Road
Burlingame, CA 94010

Planning Commission
City of Burlingame

Re. 301 Airport Boulevard

Dear Ms. Monroe and Commissioners,

Please consider the following information that may guide you when you consider the 301 Airport Boulevard proposed development as a study item on May 24th. The SFBA expects that a number of alternative development plans will be considered as called for under mitigation measure K.1.a:

"Reduce project bulk and/or place taller structures in the western portion of the site to reduce the project's effect on the wind speed on the Bay to the east of the site."To ensure that alternatives can be fairly evaluated, the alternative configurations must be tested in the wind tunnel and turbulence data must be generated. While the Commission has essentially signed off on a standard that ignores turbulence, the SFBA is likely to appeal the significant impact standard for wind impacts in order to protect the interests of windsurfers not only in the current process, but also in future processes relating to developments both inside and outside of Burlingame's borders.

The SFBA has maintained from the start of this process that an examination of turbulence was critical to evaluating impacts. While turbulence has not been incorporated into the standard set by the EIR, some examination of turbulence is needed in order for the windsurfing community to evaluate different development plans during the approval process.

Developer's Alternatives

The developer has presented the possibility that building heights could be rearranged under plans he identifies as the 44467 option and the 43477 option. While the developer has shown a willingness to shift floors from one building to another, the developer has not expressed a willingness to seriously consider options which would involve a reduction in the overall size of the project, relocation of buildings, or  rotation of buildings. Our analysis of the 43477 option, the preferable of the two, shows that it would have some mitigating effect on the wind impacts, but that the improvement would be nominal.

SFBA Suggested Alternatives

In the SFBA letter dated May 7, 1999, we suggested that a plan known as the 33355 option would better reduce wind impacts while maintaining building locations and orientations. The 33355 option would reduce the project floor area by 24%.

An alternative which incorporates building relocation or rotation also needs to be considered. I discussed alternative plans with Carl Danielson of DWI subsequent to the May 10th Planning Commission meeting. Danielson did not have any suggestions beyond the 44467 option and the 43477 option and was disinclined to explore rotation or relocation. I have attached sketches that I prepared which may serve as suggested alternatives. Ideally, the developer would participate in exploring such options. Dr. Tischler of NASA/Ames has suggested that the director of the wind tunnel at U.C. Davis might be an excellent source of advice as to alternative configurations that could reduce impacts to the wind. Dr. Tischler's experience working at a wind tunnel has led him to conclude that most wind tunnel directors have a good sense of what will or won't work based upon their experience running a broad range of projects through their tunnels.

Wind Tunnel/Evaluation of Alternatives

A number of alternative plans should be tested in the wind tunnel. Such testing will reveal the relative benefits of the different alternatives. Wind tunnel testing at this point will involve less time and expense than previous tests since the model of the development site has already been constructed. it is critical that turbulence intensity data be generated from the wind tunnel tests. It is my understanding that such data can be gathered simultaneously with the gathering of velocity data. While the commission has made a finding of sufficiency with regard to the EIR and the impact standard that ignores turbulence, the SFBA will likely challenge that standard upon finalization of the EIR. The SFBA and the windsurfing community cannot fairly give their opinion of any alternative development plan without having turbulence information to evaluate.

Turbulence

The issue of turbulence has been dismissed in the CEQA process based at least in past on flawed arguments and incorrect statements. An examination of turbulent effects is critical to evaluating the impacts to windsurfing and a turbulence standard should have been included in the EIR.

The briefing from the City of Burlingame to the Planning Commission  for the May 10 meeting stated, "Our wind experts and the windsurfing community tell us that of the component factors of wind, wind speed will have the most overt impact on the adjacent recreational user." This statement misstates the position of the SFBA and the broader windsurfing community . The SFBA has pointed out that turbulence is of critical import in letters to the City and/or the Planning Commission dated 3/6/99, 4/20/99, 4/26/99, and 5/4/99.

Charles Bennett of ESA reported in his 4/29/99 memo that a rule of thumb for wind turbulence recovery is that, "wind turbulence recovers within a distance of 25 to 50 times the building height." While it is nearly impossible to build any multi-level project without casting turbulence into the windsurfing area, the Planning Commission needs to recognize that windsurfing will suffer negative effects from turbulence and that these effects need to be reduced as much as possible to make Coyote Point Park a place where windsurfers can continue come to enjoy bay access.

SFBA Proposed Standard Dismissed

Charles Bennett of ESA suggests in his 4/29/99 memorandum that a proposed 20% turbulence intensity standard is not warranted because turbulence intensities of 20-25% are commonly encountered in locations downwind of urban development. He is correct that a standard of 20% absolute turbulence intensity is likely overly strict, but he ignores the fact that the 20% turbulence intensity standard was proposed as a relative turbulence intensity standard.

Bennett ignores the fact that the proposal for a 20% turbulence intensity standard was based upon 20% turbulence intensity as indicated by the wind tunnel tests he had conducted. The 20% turbulence intensity standard can only be used as an absolute standard and compared to actual on the water readings to the extent that the wind tunnel test has been proved accurate to calibrated with real world conditions.

Bennett indicates that in the case where a more detailed model would be used, "the expected results would be turbulence in excess of the measured existing values...". Bennett admits that the wind tunnel test likely understates the levels of turbulence and then dismisses the SFBA's proposed standard for using a turbulence intensity figure that is too low. The SFBA figure is only low to the extent that the wind tunnel tests understate the severity of the turbulence which will create an impact to windsurfing.

The SFBA used the 20% turbulence intensity figure because an area defined as 20% or more turbulence intensity under current conditions corresponded with an unsailable area near the Airport Boulevard bulkhead. If the wind tunnel tests did not understate the turbulence levels as Bennett indicates, then the unsailable area might have corresponded with a higher level of turbulence intensity, perhaps >25% or even higher. In this case the relative turbulence intensity standard proposed by the SFBA would be at the higher level associated with the unsailable area.

The wind tunnel tests may not correlate exactly with numbers measured on the water, but they will reveal what the relative advantage of one plan over another is. A comparison of the turbulence figures for current conditions and project conditions clearly shows that the area of higher turbulence intensity jumps dramatically with the project in place. In current conditions the wind tunnel showed such areas covering approximately 10% of the study area. In project condition those areas jumped to a point where they cover over 50% of the area and extend 1,300 feet past the Airport Boulevard bulkhead.

Sincerely,

Peter Thorner
Chair, Coyote Point Committee
San Francisco Boardsailing Association

5/17/99

Thanks to everyone who has helped, and keep checking back here often to see if something comes up. We will let you know when the next opportunity comes for member action.  The latest news is that the Burlingame Planning Commission has certified the E.I.R. without any finding of significant impact to windsurfing. The SFBA maintains that the planned buildings would cause VERY significant impacts, including: (1) (the E.I.R. itself reports that) the wind inside the entire 'cove' area will be harmed. Apparantly, the Commission did not find these effects or the traffic effects of the project to be 'significant'; (2) All other bay area sites will become more crowded -- especially Third Avenue, Crissy Field, and Waddell Creek/Davenport -- if the wind is ruined and launching becomes ridiculous at Coyote Point.  However, the Commission recognizes that there are impacts to windsurfing that should be addressed. At this point, it's too early to tell what is going to happen. No matter what, we will not give up!

Note: When you get a chance, be sure to thank Peter Thorner for the limitless time and energy he has devoted to this cause. His powerful and eloquent representation of our interests is the reason why we are still hanging in there.

-George Haye

3/17/99

Sorry this update is a bit tardy. I am still catching up at work after a marathon effort to complete and submit the SFBA response to the draft environmental impact report (DEIR) regarding the proposed development to be located upwind from Coyote Point. A 24-page response by the SFBA was submitted to the City of Burlingame on March 8th. The response compiled the comments received from members and from the windsurfing community at large. The cover letter and index portion of the response is appended at the end of this update. The response expressed concerns regarding the technique used in evaluating whether or not there would be a significant impact to windsurfing and also stressed the importance of Coyote Point as a resource for windsurfing.

The SFBA response, along with other letters from the public, will be forwarded to the consultants who are responsible for the contents of the environmental
impact report (EIR). It will be up to them to evaluate our concerns and address them. When they release the next revision of the EIR, it will be up to the windsurfing community to evaluate it and then let the Planning Commission know if there are any inaccuracies or concerns that were not dealt with. It will likely be a few weeks before the EIR is re-released.

To date the SFBA and windsurfing community appears to have had a significant impact on the planning process. Prior to the public meeting and comments by windsurfers, the general opinion of the city planner and environmental consultants seemed to be that the DEIR had sufficiently dealt with wind issues. After receiving input at the public meeting, by letter, and through direct meeting with the SFBA, it appears that the environmental consultant will seriously reconsider the wind issues. The consultant has already forwarded us new wind tunnel data on turbulence that seems to support our contention that impacts from turbulence may be significant. It remains to be seen how the consultant will interpret this data and relate it to impacts on windsurfing.

After the February 22nd Planning Commission meeting, which was attended by approximately 60 windsurfers, the SFBA was invited to meet with the city planner, the environmental consultants and the developer. A group from SFBA attended the meeting on March 3rd. The meeting was primarily Q&A by the
consultants who were interested in learning more about how windsurfers use the Coyote Point area. We had the opportunity to describe in detail how windsurfers use the area and we were also able to give a primer on the mechanics of windsurfing. The information on how windsurfing works helped the consultants to understand how windsurfers are impacted by gusty winds, turbulence, holes and the like. The developer and city planner were interested and involved throughout the meeting and asked a number of intelligent questions as well.

Thank you to everyone who has taken the time to participate in this effort..

Peter

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Meg Monroe, City Planner March 6, 1999
City of Burlingame
501 Primrose Road
Burlingame, CA 94010


Dear Ms. Monroe,

This document outlines SFBA's concerns regarding the office development project proposed for 301 Airport Boulevard in Burlingame. These are a compilation of the concerns of the 1,600 members of the San Francisco Boardsailing Association (SFBA) and apply primarily to the wind information in the Recirculated Draft Environmental Impact Report (RDEIR). The SFBA is a non-profit organization staffed 100% by volunteers. The SFBA was founded in 1986 to address the concerns of the boardsailing/windsurfing community in the San Francisco Bay Area. Our main goals include promoting safety, providing education, ensuring access and improving facilities. We serve the windsurfing community by working with local governments to maintain access at key sailing spots throughout the Bay Area, by working with the Coast Guard to refine safety procedures, by sponsoring races and special events for our members, and by publishing a newsletter alerting our members to upcoming events, safety issues and access issues.

The SFBA formed the Coyote Point Committee to solicit comments from the windsurfing community and to investigate the completeness and accuracy of the RDEIR. Members of the Coyote Point Committee have contacted hundreds of SFBA members as well as other members of the windsurfing community to get feedback regarding the proposed project. The combined input from these windsurfers alerted the SFBA to significant flaws in the RDEIR with regard to completeness and accuracy. The primary conclusions reached are as follows:

· The standard for significant impact, as proposed in the Wind Analysis Technical Report is insufficient. The standard accounts for changes only in average wind velocity. Examining only these changes in velocity will not reveal whether or not windsurfing will be significantly impacted. While windsurfing is seriously impacted by reductions in overall wind velocity, increases in wind range (gustiness), severe turbulence, and vortex generation also impact windsurfing conditions.

· The wind tunnel tests, which were the basis for the conclusions reached in the RDEIR, fail to account for important factors. The wind tunnel study did not examine increases in wind range (gustiness), severe turbulence, and vortex generation that will impact windsurfing. The wind tunnel study also does not account for thermal gradients which are normally present in the development area and which may have a significant impact on how far downwind destabilizing effects on the wind may be felt. The wind tunnel methodology also has very limited capabilities when it comes to describing wind behavior near the surface of the water which is the only place that wind impacts are significant to windsurfing.

· The real world experience of windsurfers points to impacts far more serious than those suggested by the wind-tunnel study and the RDEIR. Many windsurfers have reported noticeably significant impacts, including highly disturbed airflow, as far as ½ mile to 1 mile downwind from buildings in the 100' height range.

· Coyote Point Park is an irreplaceable resource for windsurfing in the San Francisco Bay Area. The park offers excellent conditions for all levels of windsurfers and has a greater parking and launching capacity than all other San Mateo County bayside windsurfing sites combined.

· The alternative development proposals outlined in the Draft Environmental Impact Report (DEIR) fail to meet CEQA requirements for a reasonable range of alternative proposals. The alternative development plans leave in place all of the proposed structures that are most likely to have a negative impact on windsurfing. No alternatives with lesser impacts are proposed.

· If the impact of the project upon windsurfing cannot be convincingly assessed, then any planning decision made needs to err in favor of protecting the existing windsurfing use. This is especially true in light of BCDC guidelines. The BCDC guidelines established for the area of the development require that a project should be designed to encourage the use of the adjacent public-access areas by the public. A development that has any negative impacts on windsurfing would not only fail to meet the BCDC guidelines, it would be in direct contravention to those guidelines.

· Since impacts to windsurfing are underestimated, no mitigation is examined in the RDEIR. However, Coyote Point Park is an irreplaceable resource for windsurfing in the San Francisco Bay Area. The park offers excellent conditions for all levels of windsurfers and has a greater parking and launching capacity than all other San Mateo County bayside windsurfing sites combined. The park is the only launch site in the Bay Area with amenities such as restrooms, showers, a snack bar, grass rigging areas and a full service shop and rental facility within walking distance. It is unlikely that another site could be established as mitigation for the loss of Coyote Point.

The conclusions listed above are in summary form. Please refer to the attached appendices for more detailed information and additional points regarding these conclusions.

In the judgment of the SFBA, the RDEIR and incorporated Technical Report are inaccurate and incomplete since the reports conclude that there is no
significant impact to windsurfing from the proposed project. In light of the points raised above, we feel further efforts to quantify the impacts to
windsurfing should be made. It is likely that the impacts to windsurfing will be hard to quantify and understand through modeling and wind tunnel testing,
especially for anyone who is not familiar with the mechanics of windsurfing. The SFBA and its members are willing and ready to participate in the planning
process and to share their knowledge of windsurfing so as to improve the process.

In addition to the wind impacts, many members of the SFBA have noted that the proposed project exceeds the height limit and the lot coverage limit
established by the City of Burlingame design guidelines for the project area. The SFBA strongly opposes approval of a variance that would allow construction of any project that exceeds established design guidelines. The SFBA is also concerned with project impact to views from Coyote Point Park and to traffic in the Coyote Point area.

While the SFBA response deals primarily with wind impacts, we have also heardmany comments by members of the windsurfing community who are concerned about
traffic impacts. Many windsurfers reach Coyote Point Park by coming eastbound on Airport Boulevard. Others regularly stop at the ASD windsurfing shop prior to windsurfing and then return to the park on eastbound Airport Boulevard. Trip generation estimates in the DEIR and RDEIR may fail to account for windsurfing traffic which is generally seasonal and which may not occur even in season during periods of low wind.

We have heard many comments by members of the windsurfing community who are concerned about traffic impacts. Many windsurfers reach Coyote Point Park by coming eastbound on Airport Boulevard. Others regularly stop at the ASD windsurfing shop prior to windsurfing and then return to the park on eastbound Airport Boulevard. Most of the windsurfers leave Coyote Point to go south on 101 via the overpass at Popular Avenue and the southbound ramp at North Amphlett road. The RDEIR indicates that the existing Level of Service for southbound traffic to 101 is F - which is extremely poor. In addition to further impacts to this intersection, we anticipate that since the limited access from the proposed development to southbound 101 is confusing, the adjacent residential area will experience significant additional traffic. Furthermore, trip generation estimates in the DEIR and RDEIR, which are limited to peak commute traffic, may fail to account for windsurfing traffic which is generally seasonal and which may not occur even on some days in season during periods of low wind. The proposed project has significant and unmitigated impacts to wind, views and traffic, which are not fully documented in the RDEIR. In light of these failings, we strongly oppose finalization of the RDEIR by the City of Burlingame.

Sincerely,

Peter Thorner
Chair, Coyote Point Committee



Cc: William Robberson
President, SFBA



APPENDICES


A. DEFINITION OF SIGNIFICANT IMPACT 5

B. WIND TUNNEL TEST METHODOLOGY 8

C. REAL WORLD CASES 10

D. COYOTE POINT AS A WINDSURFING RESOURCE 11

E. BAY CONSERVATION & DEVELOPMENT COMMISSION 13

F. ALTERNATIVES REQUIRED UNDER THE CALIFORNIA 14
ENVIRONMENTAL QUALITY ACT

G. DIAGRAM SHOWING PRIMARY SAILING AREAS 15

H. LETTER FROM MIKE GODSEY REGARDING WIND 17
TUNNEL STUDY

I. LETTER FROM BUCK LYONS REGARDING WIND 19
SHADOW EXPERIENCE IN ARUBA

J. E-MAIL FROM GLENN TAYLOR REGARDING WIND 21
SHADOW EXPERINCE AT REDWOOD SHORES

K. LETTER FROM GREG HARRIS REGARDING WIND 22
DATA COLLECTED AT SFO

2/12/99

Windsurfers,

We are nearing our last chance to have our say about development upwind of Coyote Point Park on the San Francisco Bay. The development plan calls for
five buildings on the drive-in property located at 300 Airport Boulevard. The tallest building (105' tall plus another 10' of mechanical sheds) will be located at the southeast corner of the property, closest to the launch areas. The City of Burlingame has released a study which concludes that the five structures have no significant impact on windsurfing.

The City Planning Commision is now taking comments from the public (this means you!). A Plannning Commision meeting open to the public will be held on
Monday, February 22nd at 7:00 pm. and letters may be sent to the City Planner up until March 8, 1999.

What you can do:

1. Read the recirculated draft environmental impact report (RDEIR)

The City has had a wind-tunnel study conducted by a consulting firm. The study sets its own standard for 'significant impact' and then concludes that the
wind-tunnel tests prove no significant impact. Anyone with a degree of technical ability should read the RDEIR so that you can make intelligent
comments on the assumptions and methods (Although we still want you at the Planning Commmision meeting even if it does look like a foreign language to
you!)

You can find a link to the RDEIR and updates by George Haye who has worked diligently to bring this project to the attention of the community at:
http://www.sfba.org/coyote_status.htm

You will need Adobe Acrobat to read the online copy of the RDEIR. We also plan to have a printed copy of the RDEIR at most windsurfing shops
by Saturday, February 13th ( ASD, Windsurf Bicycle Warehouse, Helm, City Front, Berkeley Windsurfing, Boardsports Marin & Berkeley ). If you are an
SFBA member, look for your alert card in the mail.

2. Come to the Planning Commission meeting on February 22nd @ 7 pm

Burlingame City Council Chambers
501 Primrose Road
Burlingame, CA 94010

The Planning Commission will take testimony from the public. They will likely expect testimony to relate to information in the EIR, so the more you've read,
the better prepared you will be to make an impression.

3. Come to ASD before the Planning Commission meeting on February 22nd @ 6 pm

ASD/Advanced Surf Design
302 Lang Road
Burlingame, CA 94010

We will have a meeting at ASD one hour before the public meeting to deliver updates and developments. Everyone is encouraged to attend this meeting as
well.

4. Sent your comments to the City Planner:

City of Burlingame Planning Department
Attention: Meg Monroe, City Planner
501 Primrose Road
Burlingame, CA 94010

Comments must be received by March 8, 1999 at 5:00 p.m. Please sent your comments earlier as so that the City Planner will have more time to read them
and incorporate them into the final EIR.

- - - - - - - - - - - - - - - - - - - - - - - - -

A few questions that have been posed:

The consultant's report proposes the following standard for define a 'significant adverse impact' to windsurfing:

"A reduction of 10% or more in wind speeds at irreplacable launching and landing sites, or a reduction in wind speed of 10% or more over large portions
of transit routes or primary board sailing areas..."

If you have a problem with this definition let the City know.

- Should the standard account for gusts or turbulence from buildings?

- Is the increased differential between the wind velocity in the channel vs. the wind velocity at the beach more important that just looking at changes in
wind velocity measured on the inside? Will people have to rig bigger to get out and end up sailing more overpowered?

- The standard allows for reductions of wind in excess of 10% in transit areas if they do not cover "large portions." Does that mean that there still might
be localized holes that can leave you in the water?

- Does the use of the term "irreplacable launch sites" allow for the beach near ASD to be excluded from the 10% maximum wind loss that the Coyote Park
Point Beach would enjoy?

Remember, If this definition of "significant adverse impact" is accepted, it may be drawn upon in the future by other planners and consultant.

Please keep your eyes open for a follow on e-mail summarizing more of the concerns that readers of the report have pointed out to date.

Peter Thorner
(415) 454-3522
(510) 547-4422
eyes4hire@aol.com

additional contact:

Greg Harris
(650) 694-8173
harris4life@yahoo.com

1/28/99
Kick the 1999 season off right by helping protect Coyote Point!

Thanks to everyone who voiced concern about the wind at Coyote Point being diminished by the new buildings planned at the old Drive-In movie theatre site (301 Airport Boulevard). The City of Burlingame has studied the issue, and has published the results of the wind study. The study reveals that the wind at Coyote will be decreased by the new development, but the City has decided that NO mitigation measures are required, and that the development may go forward as planned! Since the new development will decrease the wind speeds and will cause increased turbulence in the "inside" area at Coyote Point, those of us who want to see the damage minimized must tell the City why. Some ideas: A decrease is a decrease. The wind study predicts decreases in wind up to 5% and 10% and even up to 50% in some places, in  some scenarios. So: (1) the City should not grant any special permits to exceed height limits; (2) the City should allow construction of only a minimal number of building(s); (3) Any building(s) should be located in the southwest corner of the Project property to minimize the wind   shadows.

- 1 - READ THE NEW RECIRCULATED DRAFT EIR (RDEIR), by clicking the following link. *Anyone with or without a technical background who can critique the wind study, please let us and the City hear from you!* RDEIR (Adobe Acrobat format - 5.8 MB)
Note: The "cumulative development" referred to in the RDEIR is the current 301 Airport Boulevard project plus the 300 Airport Boulevard Project. The 300 Project is not a reality yet -- the parcel north of the Drive-In location, right on the water, from the east end of Fisherman's park (the rip-rap we see when sailing) all the way to the old   paddle-wheel ship in the little channel is zoned for a very large Hotel. A proposal to develop this land could be accepted this year, or it could  be years down the road. We'll have to stay tuned.

- 2 - EVERYONE, SEND YOUR COMMENTS (long or short, technical or personal [i.e. how you feel about Coyote] ) to: City of Burlingame Planning Department, Attention: Meg Monroe, City Planner, 501 Primrose Road, Burlingame, CA 94010. (Comments must be received by 5:00 P.M. on March 8, 1999.)

- 3 - JOIN US ON FEBRUARY 22, 1999 at 7:00 P.M. in the Burlingame City Council Chambers, to show your support for Coyote and for our windsurfer representatives who will speak at the meeting. *All Burlingame resident-sailors are particularly encouraged to attend.*

HELP KEEP COYOTE HOWLIN'!
George Haye
SFBA Member

Planning Commission Inundated With Letters & Faxes - Asks for Further Study!

November 19, 1998:
The City of Burlingame reports that they have never received so many public comments on a project! Over 350 faxes and letters poured in, from
as far away as England, Texas, Hawaii, Berkeley... The City is now obligated to study the issue (the project's effect on Coyote Point) and
include it in the Final EIR. We will need to review that Final EIR and Response to Comments Document (which should be available sometime
between now and February) and plan our response to it.

Then, we will need to turn out in big numbers at the Planning Review Meeting – to show that we do not want to see Coyote Point ruined for windsurfing, and that the proposed project must be modified. The Planning Review meeting for the 301 Airport Boulevard project should occur some time between January and March. We will need to monitor the Burlingame Planning Department’s agendas. When we find out when the public Meeting will occur, the SFBA will attempt to notify as many people as possible.

Stay tuned. Otherwise, the off-season may be forever at Coyote Point.

George Haye