2.
Response
to
Comment
2.4
Master
Responses
to
Comments
windsurfing
area
16
even
under
existing
conditions
with
a
natural
range
of
TI
values
well
above
the
criteria
in
CPA’s
sensitivity
analysis.
The
methodology
offered
by
CPA
is
much
the
same
as
that
used
in
the
Draft
EIR,
with
the
exception
of
the
concept
of
“Required
Conditions.”
Although
the
CPA
offers
a
more
complex
alternate
method
of
analysis,
it
offers
no
substantial
evidence
in
support
of
its
assertion
that
the
method
is
applicable
and
that
it
is
a
better
indicator
of
the
overall
impact
of
the
proposed
Baylands
development
on
the
CPSRA
windsurfing
area
than
the
method
used
in
the
Draft
EIR
and
for
the
Executive
Park
development
in
San
Francisco.
Moreover,
CPA’s
“Required
Conditions”
are
presented
without
supporting
evidence
that
they
are
necessary
and/or
appropriate
for
all
users
of
the
CPSRA
windsurfing
resource
or
specifying
what
types
or
classes
of
users
the
“Required
Conditions”
are
designed
for.
The
stated
minimum
mean
wind
spe
ed
of
16
miles
per
hour
(mph)
for
a
“Sailable
Observation”
is
20
percent
higher
than
the
13-mph
speed
considered
to
be
the
minimum
required
for
windsurfing
(see
Draft
EIR
page
4.M-10).
Also,
the
wind
tunnel
analysis
undertaken
for
the
Draft
EIR
showed
that
the
highest
wind
speed
reduction
occurred
under
the
wind
direction
excluded
from
the
“Sailable
Days
Impact
Analysis”
(see
Figure
21
in
Draft
EIR
Appendix
J).
The
reasons
for
not
considering
these
aforementioned
points
when
defining
the
“Required
Conditions”
are
not
clear.
No
information
is
provided
by
CPA
on
the
method
used
to
develop
the
“Required
Conditions,”
including
consideration
of
the
beginner
to
intermediate
users
that
use
the
site.
The
commenter
argues
that
the
“Required
Conditions”
are
similar
to
those
used
by
the
34
th
America’s
Cup
Regatta
in
determining
“minimum
acceptable
as
well
as
maximum
safe
racing
conditions,”
but
does
not
explain
how
the
considerations
that
apply
to
the
AC72
boats
used
in
the
34
th
America’s
Cup
translate
to
users
in
the
C
PSRA
windsurfing
area.
Therefore,
the
“Required
Conditions”
appear
to
be
a
subjective
preference
rather
than
objectively
defined
conditions
that
establish
the
“availability”
of
the
windsurfing
resource.
When
CPA
attempts
to
implement
the
alternative
method
in
its
comments,
it
does
not
show
that
even
the
alternative
method’s
first
step,
“Identify
a
data
source
that
measures
absolute
levels
of
wind
flow
that
is
calibrated
and
correlated
with
on-the-
ground
conditions
at
the
Resource,”
was
carried
out.
CPA’s
“Sailable
Day
Impact
Analysis”
using
a
“CPSRA
Sensor”
does
not
show
how
the
sensor
was
“calibrated
and
correlated
with
on
-the-
ground
conditions”
for
the
following
reasons:
Comparing
the
day’s
wind
speed
readings
with
the
day’s
windsailing
experience
is
not
a
“calibration.”
The
“CPSRA
Sensor”
is
mounted
on
a
mast
atop
a
building
and
is
likely
affected
by
the
aerodynamic
wake
of
the
building,
so
it
may
show
readings
that
are
not
truly
representative
of
the
wind
conditions
in
the
atmospheric
boundary
layer.
Further,
building
wake
effects
can
vary
for
different
wind
directions.
Note
that
for
such
cases,
the
United
States
Environmental
Protection
Agency
recommends
using
a
wind
tunnel
to
establish
factors
for
correcting
the
wind
sensor
readings
to
true
values.
as
such
by
windsurfing
enthusiasts.
16
While
there
is
no
commonly
accepted
definition
of
a
“premier”
windsurfing
area,
CPSRA
is
commonly
referred
to
Brisbane
Baylands
Final
EIR
2.4-101
May
2015