2.
Response
to
Comment
2.4
Master
Responses
to
Comments
To
determine
whether
proposed
Baylands
development
would
substantially
degrade
the
windsurfing
recreational
resource
by
reducing
wind
speeds
to
the
point
where
the
reductions
would
adversely
affect
windsurfing
in
prime
windsurfing
areas
or
substantially
impair
access
to
prime
windsurfing
areas
from
existing
launch
sites,
thereby
resulting
in
a
significant
impact
under
CEQA,
the
wind
analysis
for
the
Brisbane
Baylands
Draft
EIR
qualitatively
evaluates
two
variables:
relative
wind
speed
and
turbulence
intensity.
These
two
variables
directly
characterize
the
physical
changes
in
wind
conditions
in
the
atmospheric
boundary
layer
that
would
be
caused
by
Project
Site
development.
While
large-scale
weather-related
or
diurnal
winds
provide
the
wind
speeds
and
directions
that
enable
windsailing
in
CPSRA,
these
larger-scale
winds
are
unrelated
to
the
local
physical
development
on
the
Project
Site.
(See
Windsurfing:
Alternative
Analysis
Methodology,
for
more
discussion.)
However,
the
local
wind
speed
and
direction
are
the
most
common
primary
indicators
used
by
windsurfers
of
all
skill
levels
to
judge
whether
or
not
to
go
windsailing
on
any
given
day.
The
Draft
EIR
focuses
on
the
Project
Site
development-related
changes
in
wind
speed
that
would
occur
for
each
critical
wind
direction
as
the
most
important
and
direct
indicator
of
the
potential
adverse
effect
of
proposed
Baylands
development.
Project
Site
development
would
increase
the
“surface
roughness”
(or
effective
resistance
to
the
wind)
of
the
site,
compared
to
the
existing
site
conditions,
and
would
cause
measurable
decreases
in
wind
speed
and
increases
in
wind
turbulence
downwind
that
could
decrease
the
desirability
of
the
CPSRA
windsurfing
resource.
Because
the
considerations
of
wind
speed
and
turbulence
are
vital
to
maintaining
the
CPSRA
windsurfing
resource,
the
Draft
EIR
sets
out
to
quantify
these
changes
in
order
to
assess
the
physical
effect
of
the
Project
on
the
CPSRA
windsurfing
resource.
The
threshold
of
significance
used
in
the
Draft
EIR
is
based
in
part
on
the
recognition
that
the
CPSRA
windsurfing
area
is
an
important
windsurfing
site
in
the
San
Francisco
Bay
Area,
and
that
the
City
should
consider
subjective
as
well
as
objective
factors
in
protecting
against
a
substantial
degradation
of
that
resource
(see
Draft
EIR
page
4.M-11).
The
CPSRA
area
is
bounded
only
on
the
west
and
north,
so
changes
in
one
fraction
of
the
open
area
would
not
effectively
reduce
the
desirability
of
the
windsailing
resources,
since
changes
in
one
fraction
of
the
open
area
would
not
reduce
the
sailable
area,
but
rather
may
change
the
part
of
the
area
preferred
by
each
individual
windsurfer.
There
were
no
known
critical
thresholds
in
wind
speed
or
wind
speed
reduction
that
would
cause
a
substantial
degradation
to
the
CPSRA
windsurfing
resource,
with
the
exception
of
the
threshold
used
in
the
Executive
Park
EIR
(see
Draft
EIR
page
4.M-11).
No
absolute
minimum
thresholds
are
known
over
the
CPSRA
windsurfing
area
to
prevent
a
substantial
degradation
of
the
windsailing
resource.
In
its
comment
letter,
the
Candlestick
Preservation
Association
(CPA)
asserts
that
a
significant
impact
to
the
CPSRA
windsurfing
resource
would
result
from
Project
Site
development.
The
comment
letter
proposes
a
different
threshold
of
significance
and
an
alternative
method
of
evaluating
the
impacts
of
proposed
Baylands
development.
As
discussed
through
the
City
determined
the
threshold
and
alternative
analysis
methodology
suggested
in
Brisbane
Baylands
Final
EIR
2.4-92
May
2015