Dear Planning Commission and City Council,
I am submitting comments on the Draft Environmental Impact Report (DEIR) for the 1005 O’Brien / 1320 Willow project. My primary concern is that the DEIR does not adequately analyze or mitigate impacts on Belle Haven, a community already experiencing elevated pollution burdens and cumulative environmental stressors.
Traffic and Neighborhood Impacts
The DEIR does not clearly evaluate the risk of cut-through traffic and spillover parking into Belle Haven. Given existing congestion on Willow Road and Highway 101, diversion into residential streets is foreseeable.
• Where is cut-through traffic in Belle Haven analyzed, and what evidence supports the conclusions?
• What enforceable measures will prevent diversion and parking spillover?
• Will the City commit to a traffic and parking enforcement plan in Belle Haven, and how will it be funded and monitored?
Air Quality, Health Risk, and Environmental Justice
The DEIR does not appear to adequately address cumulative pollution exposure or disproportionate health risks.
• What are the existing baseline pollution levels (PM2.5, diesel particulate matter), and how are they incorporated into the analysis?
• Was a Health Risk Assessment conducted that accounts for existing background exposure, and what are the resulting cancer risk estimates?
• If the area is already overburdened, what evidence supports a conclusion of less-than-significant cumulative impact?
• How does the project comply with the City’s Environmental Justice Element, specifically regarding disproportionate impacts on nearby communities?
Transportation and Project Design
• What trip generation assumptions were used for life sciences uses, and how do they differ from standard office assumptions?
• How does the DEIR justify the proposed parking supply, and has induced demand been evaluated?
• What TDM measures are enforceable, and what corrective actions are triggered if performance targets are not met?
Tribal Cultural Resources
The DEIR does not clearly disclose the extent of tribal consultation or the identification and protection of tribal cultural resources.
• Which tribes were consulted under AB 52, and did any request formal consultation?
• What specific measures, including tribal monitoring, are required during ground-disturbing activities?
• What authority exists to halt construction if resources or human remains are encountered, and how will this be enforced?
Mitigation and Accountability
• Which impacts remain significant and unavoidable, and where are they clearly disclosed?
• What monitoring, reporting, and enforcement mechanisms will ensure mitigation measures are effective over time?
Given the existing environmental conditions in Belle Haven, the DEIR should include a more robust cumulative impact analysis, enforceable mitigation measures, and a clear plan to prevent additional burdens on nearby residents.
Thank you for your consideration.
Sincerely,
Eduardo L. Hernandez
District 1 Resident
