Ms. Sandy Olliges

Dear Ms. Olliges:

On behalf of the Alliance for a New Moffett Field, I am pleased to have the opportunity to comment on NASA's Draft Environmental Impact Statement (EIS) for the Ames Development Plan. We appreciate the professional approach taken by your office and your contractors, as well as the significant resource commitment that went into developing the draft.

However, we believe that the Draft EIS contains serious deficiencies. More important, both the Draft EIS analysis as well as our own additional review suggest that NASA must more thoroughly mitigate the housing, traffic, and other environmental impacts of the proposed development. In other words, the project should be scaled back or delayed until those impacts are alleviated.

1. The Baseline. In general, the Draft EIS understates the environmental conditions that would result from the proposed development by ignoring "approved" but un-built development on adjacent parcels. For example, the "lab project" included in the baseline land use plan is likely to create an additional shortfall of as many as 2,000 housing units, compared to today's conditions. That finding should be incorporated into the socio-economic analysis. Similarly, if any of the traffic-related findings ignore the impact of un-built baseline projects, they too should be updated.
 

2. Housing. The proposed Development Plan's calculable impact on the local and regional housing shortage should be more thoroughly analyzed and mitigated. The worsening jobs-housing imbalance not only threatens the quality of life and economies of surrounding communities, but it will make it difficult for NASA and its partners to attract world class employees and students to the Research Park.

A. Have all the housing requirements likely to be generated by the proposed development been identified? Have student housing needs been adequately estimated? That is, do NASA's university partners know what mix of graduate and undergraduate students they expect to bring to Moffett Field? Do they know how many full-time vs. part-time students will take part in local academic programs? Do they expect the students to commute or reside on base? Is NASA including in its estimated the increased demand for service (food services, landscaping, janitorial, etc.) employees and other work which is typically contracted out?

Furthermore, if NASA and its partners "fill up" planned buildings to the intensity estimated in the plan, will they continue to hire employees and/or recruit students? The history of local companies suggests that intensity of use increases over time. Perhaps NASA should impose and document strict limits on jobs or students per floor area.

Finally, will the housing built in support of the project match the range of income levels of prospective employees and students? Will service workers and students be priced out of the market? Will well paid professionals shy away from the high density housing proposed by NASA?

B. Will Moffett Field development, both in the Baseline and Ames Development Plan, add to the regional allocation of "fair share" housing units to the adjacent cities. Presumably no such state requirement applies to NASA, but because it lies within the spheres of influence of both Mountain View and Sunnyvale, Moffett's employment increase could burden the cities' planning goals.

C. NASA has not done an adequate job exploring additional locations for housing. The site where NASA plans major housing construction, the Bay View parcel, is unsuitable for development (see below), so NASA must find even more land upon which to construct badly needed housing. NASA should consider off-base housing; it should consider a partnership with the Army to increase the use of property currently occupied by military housing; and it should evaluate possible housing construction on the airfield and East side of Moffett Field should the Air National Guard decide to relocate.

Furthermore, NASA should more carefully consider the long-term limitations on housing resulting from hazardous waste contamination. Many of us in the local community have worked with the Navy, the MEW companies, and the regulatory agencies for more than a decade to ensure that Moffett Field's cleanup objectives would allow unrestricted use. What portions of Moffett are currently clean enough for unrestricted uses? When will other portions be clean enough to support housing? To what degree can innovative construction techniques reduce exposures while cleanup is still taking place?

D. The proposed Research Park won't work if there is no place for students and employees to live. Therefore, job-creating construction should not be approved until adequate housing construction is approved and underway.
 

3. Traffic and Air Pollution. The Draft EIS does not adequately describe, and it clearly does not sufficiently propose to mitigate the traffic and resulting air pollution impacts that will result from the preferred alternative. Again, this will not only impact surrounding communities. It will discourage potential employees and students.

A. By providing only a small amount of housing, it will appreciably increase regional traffic. The best way to mitigate regional transportation requirements is to build more housing on or near Moffett.

B. By proposing to locate housing a distance from the light rail line, the core research park, and other facilities, it increases the likelihood that residents will drive in the course of their daily business. NASA should find ways to construct more housing near established transportation corridors.

C. The proposed traffic mitigation measures are admirable, but there is no assurance that they will work, even at the levels suggested in the Draft EIS. Is NASA prepared to scale back development if early mitigation measures fail?

D. There appears to be no analysis of the capacity of local bike routes and trails to absorb additional bicycle commuters.

E. NASA should more fully estimate the number, routes, and timing of dump-trucks, other large trucks, and construction equipment. These will have a much more significant impact upon traffic and air pollution than other vehicles. Though NASA promises construction will be managed to reduce the generation of dust, will it take similar care to ensure that the dump trucks don't release dirt (and windshield-damaging rocks) on local and regional roadways.

F. NASA has found that its proposed development "would result in population and vehicle-use projections that are inconsistent with regional air quality planning, and in emissions of air pollutants from automobiles and construction equipment which would exceed significant thresholds established by the BAAQMD." How might such a result influence the South Bay Area's eligibility for federal transportation funding?
 

4. Bay Fill. NASA's proposal to fill the Bay View parcel is absolutely unacceptable. It will undermine efforts to implement regional goals for restoring the San Francisco Bay and adjacent habitat, and it will jam our roadways with 34,000 new truck trips.
 

5. Security. NASA's proposal to move back the security perimeters at both the historic Ames labs and the airfield is an excellent idea. However, NASA should develop a flexible plan to make it possible to adjust those perimeters should public uses be approved in currently restricted areas. For example, at some point the golf course could be opened to the general public, or the proposed ferry terminal might be built at Moffett.
 

6. Noise. NASA appears to fail to recognize fully that noise from existing activity at Moffett is likely to discourage people from working, studying, and living there.

A. Contours showing average noise levels do not fully represent the impact of noise on communities. NASA should evaluate the interruptive quality of aircraft operations, engine tests, and wind tunnel operations as well.

B. NASA should propose mitigation that includes control at the sources of noise, and Draft EIS assumptions based upon current flight activity and wind tunnel operations should be written as strict limits into Moffett Field's planning and management documents.

C. Even if buildings are designed to limit indoor noise from outdoor activity, Californians spend a good deal of time out of doors and do not appreciate loud or intrusive noises. NASA should therefore consider ways to mitigate outdoor reception of noise in the research park, housing areas, and associated recreational facilities.

7. Air Safety. Though the active Moffett runways are near the proposed development, the Draft EIS appears not to address air safety issues. Should there be restrictions on building heights? Are proposed development areas sufficiently buffered from aircraft operations?

8. Community Design. At its public meetings, NASA displayed some attractive nominal designs for the proposed research park. We are confident that NASA, if it wins approval for the project, will insist upon the construction of nice-looking buildings and grounds. However, we believe it should go a step further. Instead of simply calling an industrial development a campus, we believe NASA and its partners have an opportunity to create a campus that integrates research space, housing, services, and transit. Such an approach would not only make development more compatible with the surrounding communities, it would help NASA achieve its own "world-class" goals.

In summary, we believe NASA's proposed world-class research park is a good idea, but its quick construction is not essential to NASA, its partners, or our local communities. NASA must figure out, in consultation with its neighbors and regulatory agencies, how to create an environmentally sensitive plan before it moves ahead with its proposal. Such a plan would not only benefit neighboring communities and NASA's current employees, but the world-class talent-and their families-that NASA hopes to attract to the research park campus.

Sincerely,

Lenny Siegel