2.
Response
to
Comment
2.4
Master
Responses
to
Comments
Description
of
CPA’s
Alternative
Impact
Analysis
CPA’s
suggested
impact
analysis
methodology
uses
lull
and
gust
wind
speeds
in
addition
to
wind
speed
and
turbulence
to
determine
an
availability
of
the
resource;
however,
lull
and
gust
wind
speeds
are
existing
larger-scale
weather
events
that
are
independent
of
the
effects
of
proposed
development
on
the
CPSRA
windsurfing
area
(as
described
under
“Background
Information”
above).
In
Comment
CPA
2-
35,
CPA
argues
for
the
establishment
of
“minimum
plan
n
ing
conditions”
(speeds
at
whic
h
the
dynamic
force
or
“lift”
of
the
moving
sailboard
raises
it
partially
out
of
the
water,
decreasing
its
drag
or
resistance
to
motion
in
the
water)
in
all
locations
of
the
windsurfing
area
as
the
sole
determinant
of
the
“availability
of
the
resource.”
Th
is
suggestion
ignores
the
fact
that
all
users
of
the
area
may
not
have
the
same
skill
levels
and
interests.
As
discussed
in
the
Draft
EIR
(page
4.M-11),
no
minimum
conditions
are
established
for
windsurfing
over
CPSRA.
Evaluation
of
CPA’s
Alternative
Impact
Analysis
CPA
comments
provide
a
sensitivity
analysis
on
sail
force
by
changing
turbulence
intensity
using
a
correlation
equation
relating
turbulence
intensity
to
gust
and
lull
wind
speeds,
but
do
not
show
how
proposed
Baylands
development
might
affect
gusts
and
lulls,
which
are
larger-scale
weather
events.
Furthermore,
CPA’s
alternative
analysis
attempts
to
relate
Baylands
development
-related
decreases
in
wind
speed
and
increases
in
turbulence
to
the
wind
lulls
and
gusts
that
now
occur
and
will
continue
to
occur
in
the
area,
independent
of
the
Project.
These
wind
lulls
and
gusts
span
a
range
of
wind
speeds
roughly
an
order
of
magnitude
greater
than
the
effects
of
proposed
Baylands
development.
Tying
these
independent
wind
phenomena
together
with
Project
impacts
complicates
the
determination
of
the
impacts
of
Project
Site
development
on
the
CPSRA
windsurfing
resource
and
would
obscure
potential
Project
impacts
by
conflating
them
with
naturally
occurring
conditions.
In
Comment
CPA
does
not
put
into
perspective
the
range
of
turbulence
intensity
(TI)
that
is
presented
in
the
sensitivity
analysis
or
the
effects
of
the
range
of
TI.
CPA
presents
the
effects
of
a
range
of
turbulence
values
on
sail
force,
but
does
not
discuss
how
it
is
possible
to
address
the
effects
of
this
wide
natural
range
of
turbulence
under
existing
conditions
but
not
possible
to
address
a
much
smaller
range
of
TI
values
that
would
occur
due
to
Project
Site
development.
Under
existing
conditions,
the
range
in
TI
values
at
a
point
in
the
CPSRA
windsurfing
area
over
time
could
vary
by
an
amount
similar
to
that
presented
in
CPA’s
sensitivity
analysis.
For
example,
TI
measured
at
the
Brisbane
Baylands
site
at
a
height
of
59
meters,
sufficient
to
measure
the
freely
flowing
wind,
show
TI
values
ranging
from
0.14
(14
percent)
to
0.24
(24
percent)
between
April
17,
2008,
and
December
30,
2010.
Also,
under
existing
conditions,
the
range
of
TI
over
the
CPSRA
area
is
considerably
larger
than
the
range
of
TI
presented
in
the
commenter’s
sensitivity
analysis,
as
shown
in
Appendix
J
with
the
existing
conditions
of
TI
ranging
from
0.1
(10
percent)
to
0.31
(31
percent)
over
the
CPSRA
windsurfing
area
considering
all
wind
directions
(see
also
page
4.M-11
of
the
Draft
EIR).
Therefore,
the
CPSRA
windsurfin
g
area
is
still
considered
by
the
windsurfing
community
to
be
a
“premier”
Brisbane
Baylands
Final
EIR
2.4-100
May
2015