2.
Response
to
Comment
2.4
Master
Responses
to
Comments
O
n
its
website,
the
operator
of
the
“CPSRA
Sensor”
posts
a
disclaimer
regarding
use
of
meteorological
information,
stating
that
“meteorological
information
provided
here
is
primarily
for
guidance
in
recreational
activities
in
associated
areas.”
One
commenter
blog
on
the
Windsurf
Community
Forum
complained
about
low
readings
from
a
sensor
in
the
CPSRA
windsurfing
area.
It
is
not
known
if
that
sensor
was
the
same
sensor
referred
to
in
the
“Sailable
Day
Impact
Analysis.”
This
is
that
blogger’s
opinion,
but
it
i
s
indicative
of
a
potential
“calibration”
problem.
Readings
from
a
single
“CPSRA
Sensor”
cannot
represent
the
measurements
of
the
range
of
variability
of
wind
speed
and
turbulence
over
the
windsurfing
resource.
“[O]n
-the-
ground
sailing
conditions”
are
exp
ected
to
vary
under
existing
conditions
over
the
CPSRA
area
(refer
to
the
figures
in
Appendix
J
to
see
how
wind
speed
and
turbulence
vary
over
the
test
grid
due
solely
to
upwind
surface
roughness
effects
under
existing
conditions),
and
the
variability
of
t
hese
conditions
over
the
area
(except
for
the
“wind
shadow”
noted
by
CPA)
is
not
discussed
by
the
commenter.
Although
CPA
may
correlate
wind
turbulence
and
wind
speed
to
lull
and
gust
wind
speeds,
CPA
does
not
show
how
proposed
Baylands
development
would
cause
changes
in
the
lull
and
gust
wind
speeds
that
naturally
occur.
Furthermore,
the
range
of
turbulence
intensity
cited
by
CPA
as
having
a
significant
impact
on
the
resource
is
much
smaller
than
the
natural
range
of
variability
that
now
occurs
over
the
CPSRA
windsurfing
area
under
different
source
wind
direction
conditions.
The
selected
wind
models
used
by
CPA
do
not
prove
that
Baylands
development-related
changes
in
surface
roughness
upwind
would
cause
a
change
in
gale
and
lull
wind
speeds,
but
simply
correlate
turbulence
intensity
and
mean
wind
speed
with
gust
and
lull
wind
speeds.
However,
correlation
does
not
prove
causation.
Therefore,
incorporating
gust
and
lull
wind
speeds
into
the
“Sailable
Impact
Analysis”
does
not
demonstrate
that
proposed
Bayla
nds
development
would
have
a
significant
impact
on
the
windsurfing
resource
considered.
Also,
the
validity
of
using
Extreme
Value
Theory
to
calculate
gusts
is
unknown.
According
to
the
article
cited
by
CPA,
a
near
gale
is
greater
than
14
meters/second
(14
m/s
or
31
mph).
However,
the
meteorological
tower
at
the
Brisbane
Baylands
site
that
the
City
of
Brisbane
used
to
measure
winds
at
59
meters,
a
height
sufficient
to
measure
freely
flowing
wind,
showed
that
85
percent
of
the
time
winds
measured
at
or
below
10
m/s
(22
mph);
thus,
wind
speeds
greater
than
10
m/s
occur
less
than
15
percent
of
the
time
and
winds
greater
than
14
m/s
must
occur
much
less
than
15
percent
of
the
time.
The
wind
at
a
height
of
59
meters
is
faster
than
the
wind
near
the
surface
of
the
CPSRA
windsurfing
area,
which
is
in
the
lowest
part
of
the
atmospheric
boundary
layer
where
the
speed
is
reduced
most
by
the
effects
of
upwind
surface
roughness
of
land.
Therefore,
the
reduced
speed
winds
that
windsurfers
experience
within
CPSRA
should
se
ldom
reach
the
“near
gale”
category.
Furthermore,
the
“Sailable
Day
Impact
Analysis”
includes
mean
wind
speeds
that
are
well
below
“near
gale”
to
calculate
a
reduction
in
gust
and
lull
wind
speeds.
CPA
states
that
“[p]redicted
lull
and
gust
values
using
t
his
method
are
consistent
with
sensor
observations,”
but
provides
no
evidence
of
the
causal
relationship.
Instead,
CPA
proceeds
with
the
analysis
without
demonstrating
that
the
models
used
as
its
basis
are
indeed
valid
and
actually
can
achieve
their
stated
purpose.
Brisbane
Baylands
Final
EIR
2.4-102
May
2015