|
Dear Friends,
Below is a description of the arguments heard at the San Francisco Board of Supervisors February 3 Hearing where the Board upheld the San Francisco Planning Commission’s CEQA Certification of SFO's Airport Development Plan (ADP), and denied the City of Palo Alto’s appeal.
The Appeal:
The City of Palo Alto’s appeal centered on the FEIR noise baseline and that the FEIR does not analyze noise impacts from future growth in flights that will occur as accommodated by the ADP. Per the transcript of the City of Palo Alto’s presentation: “The EIR takes the position that it can use the year 2045, as the baseline, even though normally you're supposed to use existing conditions as a baseline for its environmental analysis. If you're going to do a 2045 baseline analysis, the starting point of that analysis is you're supposed to actually describe noise conditions in the year 2045 without the project, and you compare that to the impacts that the project will cause. That threshold presentation of baseline 2045, noise impacts is completely missing from the document. The document, the chapter on noise impacts, has a discussion of summary of noise conditions that existed in the year 2019 through 2023, there's a chart that talks about decibel levels, not over Palo Alto, but in areas in the city of the airport. But there's zero discussion anywhere of future noise impacts from airport flights in 2045 and if you're really going to do a baseline analysis of 2045, conditions you have to include start with a summary of what those actual impacts are, and that's completely missing from the document.”
San Francisco’s Argument:
The San Francisco Planning Review Officer summarized their opposition to the appeal as follows: “It's important to note that we did characterize 2019 conditions, and the project, as we have explained, would not result in any increase in aircraft flights. And so the project's impact in that regard, is no impact. So if the increase from existing conditions is no impact, the increase from 2045 conditions is no impact. So the delta is very evident. So the appellant is focusing on a nuance here about a baseline, and it's evident that a reader can easily discern the important goal of CEQA environmental impact analysis, which is to understand the impact. So regardless of which baseline you choose, we've clearly explained what the project's effect would be, with regard to aircraft, and that effect, the emissions that would result, is zero. So I think, you know, they're kind of focused, like focusing, kind of grasping at something here, and over complicating something and I think that is making it more complicated than is necessary”
The 2019 “conditions” and San Francisco’s explanation for “Zero” impact from the project:
The “2019 conditions” refer to baseline measurements in the FEIR of ground traffic, transit ridership, noise, and air quality at the airport; these do not include any analysis of SFO’s Arrivals traffic. The “explanations” mentioned by the SF Planning Officer refer to forecasted 506,000 annual aircraft operations by 2045 that is used to back-calculate/estimate a corresponding passenger volume of 71.1 million annual passengers using assumptions about fleet mix (e.g., average seats per aircraft), load factors, and enplanement ratios. This estimate of 71.1 million passengers in 2045 is then deemed to be demand-driven or from external market forces; not “induced” by the project’s landside improvements. It is by virtue of these multi-step conclusions, and assumptions that the project is considered by SF Planning as having “zero” impact. The FEIR also asserted that flight paths and noise will not change because there is no runway construction (which is misleading because flight path modifications can happen and alter noise) but if indeed all that was needed for the state’s environmental rules to allow omission of noise impacts analysis was the project’s non-inducement of demand or “it’s the passengers” explanation it remains unclear why SFO devoted so much to declare there is no noise from flight paths.
Reality is that the SFO project is estimating 71.1 million passengers (from approximately 57 million in 2019 and 54 million in 2025); this means more flights, more noise and more negative impacts. An SFO slide was then added for the Supervisors Hearing "What has SFO done to address existing aircraft noise concerns" listing noise monitoring; the SFO Roundtable, and that SFO “cannot change flight procedures” (yet the FAA changes procedures for SFO with SFO’s involvement). During public comment, a Palo Alto resident clarified that SFO does not offer permanent noise monitoring to Palo Alto, and the City has been denied SFO Roundtable membership which raised the interest of one Supervisor who asked about how San Mateo County voted to keep Santa Clara County off the SFO Roundtable. Had the SFO slide been made available sooner, we would have been able to submit more about SFO's role in flight procedures. Altogether, the “zero” impact assumptions and much of what was said about noise and flight paths generate misleading information to people who stand to be negatively affected and the City of Palo Alto’s appeal for noise impacts analysis of future growth in flights that will occur with the ADP remains necessary if not even more urgent.
The purpose of CEQA:
California’s CEQA is meant to comply with the goals of National Environmental Policy which are to take a "hard look" at potential impacts; to generate adequate disclosures and discussion of alternatives. Or as the Planning Officer stated the important goal of CEQA environmental impact analysis is to understand the impact. SFO's CEQA drove the opposite outcome 1) San Francisco used a simplistic view or apparent loophole that an industrial facility has no role in disclosing pollution levels from growth in its operations as long as the growth is “demand driven;” and even as it profits from growth 2) the project’s public record misleads about flight paths; SFO's role in flight paths, and resulting noise. 3) there was no real community engagement - information dripped in at the last hours without notice which the public could not adequately respond to.
We consider it very important that Palo Alto Council insist on analysis and disclosure of SFO’s Arrival impacts by appealing this in court as well as any state rules or loopholes that could allow for such casual treatment of SFO's expansion.
The replay of the hearing is here - time code 2:34:41. Per Index click on “SPECIAL ORDER 3:00 P.M.251277 Hearing - Appeal of Final Environmental Impact Report Certification - SFO Recommended Airport Development Plan” All related documentation can be found here.
| 
