2.
Response
to
Comment
2.4
Master
Responses
to
Comments
Comment
Letter
CPA
2
to
be
less
appropriate
and
useful
than
the
methodology
used
in
the
Draft
EIR.
CPA’s
proposed
threshold
of
significance
has
never
been
applied
to
the
CPSRA
windsurfing
area
in
a
publicly
circulated
CEQA
document,
in
contrast
to
the
threshold
of
significance
used
in
the
Draft
EIR.
Also,
the
abil
ity
of
CPA’s
alternative
analysis
methodology
to
determine
the
impact
of
Project
Site
development
on
the
CPSRA
windsurfing
resource
is
less
compelling
because
it
(1)
incorporates
weather
events
that
are
not
affected
by
development
of
a
project
site,
(2)
uses
data
with
an
unknown
quality
or
calibration,
and
(3)
evaluates
the
data
against
subjective
absolute
minimum
thresholds,
referred
to
as
“Required
Conditions”
in
Comment
Letter
CPA
2.
(For
additional
discussion
of
CPA’s
proposed
wind
impact
analysis
metho
dology,
see
Master
Response
31.)
Furthermore,
the
application
of
the
models
used
to
relate
wind
turbulence
intensity
with
gust
factors
in
the
“Sailable
Day
Impact
Analysis”
of
CPA
alternative
analysis
methodology
is
not
as
reliable
as
that
used
in
the
Draft
EIR.
There
is
no
evidence
presented
by
CPA
or
other
comments
that
models
based
on
Mean
Value
Theory
are
applicable
for
determining
gust
winds
over
the
CPSRA
windsurfing
area
for
mean
winds
speeds
below
near
gale,
which
are
known
to
most
frequently
occur
over
the
area.
(See
Master
Response
31
for
additional
discussion
of
methodology).
2.4.31
Master
Response
31,
Windsurfing:
Use
of
a
Wind
Tunnel
in
Analyzing
Wind
Impacts
Comments
Several
comments
questioned
the
use
of
a
physical
model
of
Baylands
development
being
tested
in
a
wind
tunnel
to
evaluate
impacts
of
proposed
Baylands
development.
These
comments
expressed
concerns
about
both
the
accuracy
of
the
modeling
and
the
accuracy
of
wind
tunnel
testing.
Response
Measurements
of
relative
wind
speed
and
turbulence
intensity
in
the
wind
study
were
based
on
physical
testing
in
an
Atmospheric
Boundary
Layer
Wind
Tunnel.
It
is
well
documented
in
the
scientific
literature
that
such
a
wind
tunnel
can
correctly
represent
wind
velocity,
wind
turbulence,
and
the
power
spectrum
of
the
wind
in
the
boundary
layer
of
the
atmosphere.
Located
at
UC
Davis,
the
wind
tunnel
used
for
the
tests
was
built
to
simulate
near-surface
wind
flow
of
the
atmospheric
boundary
layer.
Specifically,
the
surface
layer
region
of
the
atmospheric
boundary
layer
is
well
modeled
in
this
wind
tunnel.
The
surface
layer
is
that
region
of
air
from
the
earth’s
surface
up
to
about
50
to
100
meters
in
height
and
under
neutral
atmospheric
stability
conditions,
where
the
mean
turbulent
velocity
profile
is
two-dimensional
and
is
not
substantially
affected
by
the
Coriolis
motion
due
to
the
earth’s
rotation.
Many
researchers
(Davenport
and
Isyumov,
1968;
Cermak,
1971;
Cook,
1975;
Hunt
and
Fernholz,
1975;
and
others)
have
documented
that
a
properly
designed
and
built
atmospheric
boundary
layer
wind
tunnel
will
accurately
model
the
surface
layer
of
the
atmosphere
under
neutral
atmospheric
stability
conditions.
Brisbane
Baylands
Final
EIR
2.4-93
May
2015